Document aBqjQdQNoOv5jGrJ1zX3rJdvB

From: Chaitovitz, Chuck [CChaitovitz@USChamber.com] ent: 2/14/2025 8:42:20 PM o: Zeldin, Lee [Zeldin.Lee@epa.gov] CC: Kramer, Jessica L. [kramer.jessical@epa.gov]; Durbin, Martin [MDurbin@USChamber.com]; Varcoe, Andrew [AVarcoe@USChamber.com]; Beard, Preston [PBeard@USChamber.com] ubject: Business PFAS principles and policy recommendations ttachments:250214_USCCCoalition_PolicyPrinciples_EPAAdmin.pdf Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Dear Administrator Zeldin: Attached is a coalition letter suggesting principles and policy recommendations around PFAS for your consideration. We support accelerating appropriate cleanup of PFAS in the environment, while maintaining access to essential chemistries in critical sectors across the economy. Here is a link to our report highlighting the economic impact of seven sectors making products that Americans rely on every day: https:, /www.uschamber.com/environmentiessential-chemistries-providing-benefits-across-the-u-s-economy Our top request for the agency is to withdraw the hazardous substance designation of PFOA and PFOS under CERCLA. This action should be part of EPA's efforts to meet the outcomes of the regulatory freeze and the 10 to 1 ratio of deregulation to new regulations. Perhaps we can arrange a meeting to brief you and your team on these important issues? Please feel free to contact me with questions or if I can ever be of assistance. Thanks in advance, and I look forward to following up, Chuck Chuck Chaitovitz Vice President, Environmental Affairs and Sustainability U.S. Chamber of Commerce 202-463-5316 (Phone) 202-680-8578 (Cell) cchaitovit4 uschamber.com http://www.uschamber.com For The Pursuit ED_018475D_00003367-00001 ED_018475D_00003367-00002 February 14, 2025 The Honorable Lee Zeldin Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. 4101 M Washington, D.C. 20460 RE: Business Coalition PFAS Principles and Policy Recommendations Dear Administrator Zeldin: As the Environmental Protection Agency (EPA) explores potential approaches to both recognizing the critical benefits of per- and polyfluoroalkyl substances (PFAS), and ensuring they are used safely and are appropriately cleaned up in the environment, the undersigned organizations urge your consideration of the following principles and policy recommendations: Recognize that PFAS are a broad class of chemistries with very diverse and necessary properties. It is crucial that regulatory actions recognize this diversity and calibrate the risk that individual PFAS chemistries may pose. Because all PFAS are not the same, they cannot all be regulated in the same way, including chemistries and groups of similar chemistries that would not be expected to be of health or environmental concern. A reports from an international panel on regulation and management of PFAS has concluded that, "[m]ost experts agreed that all PFAS should not be grouped together for risk assessment purposes" and "that it is inappropriate to assume equal toxicity/potency across the diverse class of PFAS." Direction from EPA that PFAS should not be regulated as a class is critical to prevent potentially conflicting state requirements that can cause supply chain and other infrastructure disruptions. Accelerate appropriate cleanup of PFAS in the environment. The agency should work with all stakeholders, including our organizations, to implement cleanup of PFAS in the environment, consistent with the best science and appropriate consideration of risk, to protect human health and the environment in communities across our nation. We urge the agency to act as appropriate through existing, non-CERCLA authorities,2 while considering the resource needs for local governments and the private sector to address other regulations and broader drinking water priorities, especially given the unattainable treatment levels established in the PFAS National Primary Drinking Water Standard, finalized in April 2024. EPA should: o Publicly support efforts to cleanup PFAS by finding ways to: https://scipinion.com/panel-findings/risk-assessment-of-pfas/ https://www.uschamber.com/environment/u-s-chamber-letter-and-report-on-cercla-alternatives-analysis 1 ED_018475D_00003368-00001 Provide additional science-based guidance on questions about innovative technologies and methods for PFAS treatment, disposal, destruction, and remediation, including by updates, as appropriate, to the EPA's PFAS Disposal & Destruction Guidance document. Speed up permitting for remediation/cleanup projects at the federal level and encourage and incentivize states to be more efficient with their permitting. Implement a more effective risk communication approach to the public. Explore and identify all viable destruction technologies, including thermal destruction as necessary tools in the PFAS cleanup toolbox. Maintain access to essential chemistries in critical sectors across the economy. The U.S. Chamber of Commerce released a report on the impacts of essential fluorochemistries, including PFAS, on seven key sectors across the economy in critical products Americans rely on every day, from airplanes to cars, cellphones, medical devices, and emerging technologies that will drive the energy transition. In addition, the Department of Defense (DoD) released a valuable report of critical uses of PFAS, highlighting the complexities and challenges of replacing various PFAS applications. The Department of Energy also evaluated the potential for alternatives to fluoropolymer applications and found similar challenges in any possible transition. These authoritative reports provide particular emphasis on the high value and low hazard of fluoropolymers and should guide the agency's deliberations. Collaborate across the federal interagency community and the agency to ensure consistent regulatory action and prevent unintended consequences. Drinking water standards, for example, can impact regulations falling under U.S. Department of Agriculture and Food and Drug Administration authority, as well as EPA. DoD, EPA, and the Federal Aviation Administration (FAA), among other agencies should continue to work together on the aqueous film forming foam (AFFF) transition and recognize the need for emergency use when substitutes are not available. While these are just two examples, a lack of agency coordination can create unnecessary confusion across agencies and for regulated industries. Relevant offices within EPA should also coordinate and integrate their approach. Establish regular engagement with the business community. A regular and consistent dialogue between the agency and the essential chemistry value chain will help inform key policies and promote innovation on the approaches and solutions proposed. This discussion can also foster a more holistic and comprehensive approach to overall PFAS management, which is critical given the interconnectedness of these various regulations and proposals. 2 ED_018475D_00003368-00002 We also recommend the agency take the following immediate actions: Propose and finalize a new rule that withdraws the previous Administration's decision to designate PFOA and PFOS as hazardous substances under CERCLA.3 Propose and finalize a new rule that would implement the traditional TSCA exemptions (e.g., de minimis, small business, articles, impurities, research) and remove the IUCLID software requirements for any studies conducted prior to 2007 from the reporting and recordkeeping requirements for PFAS provided by section 8(a)(7) of the Toxic Substances Control Act (TSCA). This streamlining should also include a refocusing of this reporting to provide EPA actionable, high-quality, information to support EPA's regulator assessments while also ensuring compliance with the Paperwork Reduction Act (PRA), the Regulatory Flexibility Act (RFA), and the Unfunded Mandates Reform Act (UMRA) including requirements to collect data with practical utility in the least burdensome manner. Coordinate this rulemaking with an administrative action to again extend the one-time TSCA reporting obligations that begin on July 11, 2025, ending on Jan. 11, 2026 (or July 11, 2026, for small businesses). Propose and finalize a new rule that re-instates the de minimis exemption for the Toxics Release Inventory (TRI) and for specific supplier notification requirements and eliminates adding all PFAS that are included in the TRI automatically to list of chemicals of special concern. Explore options to appropriately ensure the National Primary Drinking Water Standards for PFOA, PFOS, and additional select PFAS are set at workable levels. Withdraw action and reopen stakeholder engagement on EPA's rules proposing to: (1) add nine specific PFAS, their salts, and their structural isomers, to its list of hazardous constituents under RCRA; and (2) amend the definition of hazardous waste applicable to corrective action to address releases from solid waste management units at RCRApermitted treatment, storage, and disposal facilities. Support EPA policies and legislation proposing a U.S. government wide PFAS definition based on the Delaware and West Virginia laws. Bans and restrictions on PFAS should not include fluorinated gases already regulated under the Clean Air Act's SNAP policy and the American Innovation and Manufacturing Act. Propose additional funding to support cleanup of PFAS in the environment. We believe CERCLA is the wrong policy tool to accelerate cleanup. The endless liability created by CERCLA designations would slow cleanup and create untenable uncertainty for both companies and communities. The U.S. Chamber's April 6, 2023 letter to the Senate Environment and Public Works Committee urged consideration of alternative authorities that would avoid such outcomes. The Chamber also provided a cost analysis highlighting the impact 3 https://www.uschamber.com/assets/documents/Opening-Brief-Chamber-v.-EPA-D.C.-Circuit 2024-11-05170448 iuil.pdf 3 ED_018475D_00003368-00003 of a CERCLA hazardous substance designation on municipal services in representative local communities. For instance, the likely increase in the costs for a household drinking water bill is expected to be as much $400 annually, a substantial and unnecessary expense endured by families. In addition, the cost of cleanup for potentially responsible parties could total over $17.4 billion for existing non-federal national priority sites alone. Private party cleanup costs at existing non-federal sites could total $700-$900 million annually. Despite any existing uncertainties, which are qualitatively and quantitatively discussed in the Cleanup Cost Analysis, these costs are simply too large for EPA to ignore. Please feel free to contact Chuck Chaitovitz with the U.S. Chamber at cchaitovitz@uschamber.com with any questions. We stand ready to work with you on these important issues. Sincerely, Alliance for Automotive Innovation Alliance for Chemical Distribution American Chemistry Council American Coatings Association American Fuel & Petrochemical Manufacturers American Petroleum Institute Cookware Sustainability Alliance Council of Industrial Boiler Owners Fuel Cell & Hydrogen Energy Association Fluid Sealing Association National Asphalt Pavement Association National Association of Manufacturers National Mining Association National Association for Surface Finishing National Council of Textile Organizations PRINTING United Alliance TRSA - The Linen, Uniform and Facility Services Association U.S. Chamber of Commerce Valve Manufacturers Association 4 ED_018475D_00003368-00004 U.S. Chamber of Commerce Suzanne Clark President and Chief Executive Officer February 25, 2025 The Honorable Lee Zeldin Administrator Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460 Dear Administrator Zeldin: On behalf of the U.S. Chamber of Commerce, I am pleased to invite you to address the Chamber of Commerce Committee of 100 (CCC100), an elite group of state and local chamber of commerce CEOs from across the country. This group will gather from Sunday, March 16 to Tuesday, March 18 at Chamber headquarters in Washington, D.C. to discuss some of the most pressing issues facing our country and the business community today. We would like you to join us as a featured speaker at our evening session on Sunday, March 16 or at our general session on Monday, March 17, and we will work to accommodate your schedule. Your insights and vision on the EPA's role in energizing economic growth in America will greatly resonate with the audience. Nicole Rose from the Chamber's Events team will follow up with your office to facilitate your participation. In the meantime, if your staff has any questions, Nicole can be reached at 773-706-0869 or nrose@uschamber.com. Thank you for your consideration. Sincerely, Cetek,e__ 1615 H Street, NW, Washington, DC 20062-2000 202.463.1234 1202.463.2345 Fax ED_018475D_00002936-00001 Message From: Sent: To: BCC: Subject: ZeldinScheduling [/O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=9FE57F121B124618BA0CAB63352A3635-ZELDINSCHED] 3/5/2025 5:54:49 PM Nrose@USChamber.com ZeldinScheduling [ZeldinScheduling@epa.gov] RE: US Chamber of Commerce Speaking Invitation for Administrator Zeldin Hi Nicole, Thank you for the invite, but the Administrator will not be able to attend this event. Sincerely, Office of the Administrator From: Rose, Nicole . Sent: Tuesday, March 4, 2025 10:23 AM To: ZeldinScheduling ' Subject: Re: US Chamber of Commerce Speaking Invitation for Administrator Zeldin I Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Good morning, I want to follow up on our invitation and see if you need any additional information? We would love to have him join us for the evening programming on the 16th if possible. Thanks, Nicole Nicole Rose Booker/Producer Event Content and Programming U.S. Chamber of Commerce 773.706.0869 From: Rose, Nicole <Nrose@USChamber.com> Sent: Friday, February 28, 2025 12:50 PM To: ZeldinScheduling <_,_.--iInSchadullng@epa. .gov> Subject: Re: US Chamber of Commerce Speaking Invitation for Administrator Zeldin Attaching the completed form. Thanks, Nicole Nicole Rose Booker/Producer ED_018475D_00002692-00001 Event Content and Programming U.S. Chamber of Commerce 773.706.0869 From: ZeldinScheduling <ZeldinSchedulingOepa.goy> Sent: Wednesday, February 26, 2025 7:57 PM To: Rose, Nicole Jrn> Subject: RE: US Chamber of Commerce Speaking Invitation for Administrator Zeldin CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Hello Nicole, Thank you for the invite. Please complete the form. Thank you! Sincerely, Office of the Administrator From: Rose, Nicole <N!- 13 orn> Sent: Wednesday, February 26, 2025 11:10 AM To: Zeldin, Lee < leldin.Leek,epa.gov> Cc: Amidon, Eric <A77:Hc.;s 7 . I 7:Ireenter WeSleY@ePa.,7)` ; Guith, Christopher <CGuith@USChamber.com> Subject: US Chamber of Commerce Speaking Invitation for Administrator Zeldin Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Good morning, On behalf of the U.S. Chamber of Commerce, I am pleased to invite Administrator Zeldin to address the Chamber of Commerce Committee of 100 (CCC100), an elite group of state and local chamber of commerce CEOs from across the country. This group will gather from Sunday, March 16 to Tuesday, March 18 at the U.S. Chamber of Commerce headquarters in Washington, DC to discuss some of the most pressing issues facing our country and the business community today. We would like the Administrator to join for a fireside chat with a senior Chamber executive during our evening session on Sunday, March 16 or during our general session on Monday, March 17. His insights and vision on the EPA's role in energizing economic growth in America will greatly resonate with the audience. I have attached a formal invitation from our President and CEO, Suzanne Clark. We hope the Administrator is able to join this important event and we will work to accommodate his schedule. Please let me know if you have any questions. Sincerely, Nicole Nicole Rose Booker/Producer Event Content and Programming ED_018475D_00002692-00002 U.S. Chamber of Commerce 773.706.0869 ED_018475D_00002692-00003 Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. on-nIont, Oml:we. ana Su t naooity C:on es EVENT INVITE Wednesday, April 2, 2025 8:00 a.m. to 12:30 p.m. EST U.S. Chamber of Commerce Headquarters Please join us for a series of discussions of public and private stakeholders on the practical and policy solutions to address the environmental management challenges that communities and companies are facing due to per- and polyfluorinated substances or "PFAS." The dialogue will focus on developing recommendations and actions to accelerate ED_018475D_00000407-00001 cleanup of PFAS in the environment, in particular solutions for wastewater and drinking water challenges. Please register below. Outcomes: Develop a stakeholder leadership council of a select group of companies and other champions who are most vested in a dialogue to drive action on PFAS cleanup. Identify the policy and practical barriers to fostering innovation and scaling deployment of the best treatment technologies. Promote water reuse and recycling as among the mechanisms to treat and possibly eliminate discharges. Catalyze research and development in key disposal and destruction technologies. This e-mail was se dad contains informarion directly folidoci IC af subscriptionprofile %%Member Busna-ne%'''-i. ember Addr%% %% .ember City%%, %%Mernbei .State%%. %%Member_PostalCode%%. 'ember Country%% flambee- and 'U.S. CHAMBER. COMMERCE' are registered tradema,ks the Chamber of Commerce of the LI,1led States of America ED_018475D_00000407-00002 ED_018475D_00000407-00003 Message From: Chaitovitz, Chuck [CChaitovitz@USChamber.com] Sent: 3/31/2025 2:01:40 PM To: Abboud, Michael [abboud.michael@epa.gov] Subject:RE: For the Summit event Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Thanks so much Michael. Will do. From: Abboud, Michael <abboud.michael@epa.gov> Sent: Monday, March 31, 2025 9:56 AM To: Chaitovitz, Chuck <CChaitovitz@USChamber.com> Subject: For the Summit event CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. When you have this filled out, submit it to ZeldinScheduling(ajepa.gov and cc my email address. ED_018475D_00000489-00001 Message From: Chaitovitz, Chuck [CChaitovitz@USChamber.com] Sent: 3/31/2025 4:08:46 PM To: Corlett, Thomas [Corlett.Thomas@epa.gov] CC: Merrifield, Trevor [TMerrifield@USChamber.com] Subject: JOIN US I PFAS Clean Water Solutions Summit: Wednesday, April 2, 2025, starting at 8:00 a.m. Attachments:250328_PFAS Clean Water Solutions Summit_AnnotatedAgendaDRAFT_2.docx Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Dear Thomas: Attached is the latest draft annotated agenda for our upcoming PFAS Clean Water Solutions Summit for your consideration. Below is the registration link. Please let me know how else I can assist. Thanks again, and I hope you will attend, Chuck PEAS GOA VeV:3 Sdutions SumFivt Energy, Env .ore B .3bi itv CfrIterr EVENT INVITE ED_018475D_00003032-00001 Wednesday, April 2, 2025 8:00 a.m. to 12:30 p.m. EST U.S. Chamber of Commerce Headquarters Please join us for a series of discussions of public and private stakeholders on the practical and policy solutions to address the environmental management challenges that communities and companies are facing due to per- and polyfluorinated substances or "PFAS." The dialogue will focus on developing recommendations and actions to accelerate cleanup of PFAS in the environment, in particular solutions for wastewater and drinking water challenges. Please register below. REGISTER Outcomes: Develop a stakeholder leadership council of a select group of companies and other champions who are most vested in a dialogue to drive action on PFAS cleanup. Identify the policy and practical barriers to fostering innovation and scaling deployment of the best treatment technologies. Promote water reuse and recycling as among the mechanisms to treat and possibly eliminate discharges. Catalyze research and development in key disposal and destruction technologies. ED_018475D_00003032-00002