Document oDrdbbg0MM6rOD9OwOBM353eR

Message From: Chaitovitz, Chuck [CChaitovitz@USChamber.com] Sent: 5/6/2025 8:48:51 PM To: Zeldin, Lee [Zeldin.Lee@epa.gov] CC: Abboud, Michael [abboud.michael@epa.gov]; Risley, David [Risley.David@epa.gov]; Kramer, Jessica L. [kramer.jessical@epa.gov]; Durbin, Martin [MDurbin@USChamber.com]; Varcoe, Andrew [AVarcoe@USChamber.com]; Merrifield, Trevor [TMerrifield@USChamber.com] Subject: coalition letter on the PFAS Action Plan and other recommendations Attachments:250506Coalition_PFASActionPlan_OtherRecommendations_EPA.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 providing several key recommendations for the agency to consider as it develops an integrated and strategic approach to PFAS policy. As you know, the Chamber supports accelerating clean up of PFAS in the environment, based on the best science and risk management, while maintaining access to essential chemistries in key sectors across the economy. We welcome the opportunity to engage with you and your team on these important issues. Perhaps during the coming weeks? Please feel free to contact me if I can ever be of service. 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) Ex. 6 Personal Privacy (PP) ccha itovitz@ uscha m be r.com http://www.uschamber.com For The Pursuit Sierra Club FOIA 2025-EPA-08249 ED_019467A_00000254-00001 SC_EVERSPLIT0030512 May 6, 2025 The Honorable Lee Zeldin Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460 RE: A new PFAS Action Plan and other recommendations Dear Administrator Zeldin: The undersigned organizations are heartened to hear your commitment to sound, sciencebased, commonsense regulations and believe your leadership at EPA will be essential to achieving many of your goals, as outlined in the five key pillars announcement. As collaboration between industry and regulators is vital to right-size policy solutions for implementation, we appreciate your early engagement with the business community to better understand our challenges. Many of our organizations sent a letter of onnciples and policy recommendations to you on February 14, 2025.1 Among our highest priorities is to appropriately accelerate the cleanup of PFAS in the environment, based on sound science and risk management best practices, while maintaining access to essential chemistries in critical sectors across the economy. To achieve these goals, a number of decisions made by the prior Administration must be corrected and, in some instances, reversed. Accordingly, the following are several key issues and actions for your consideration: Partner with experts across EPA, other agencies, and the broad stakeholder community to update the PFAS Action Plan and implement a commonsense and integrated strategy that focuses on appropriate and effective cleanup of PFAS in the environment. Our organizations support you, EPA, and the U.S. government in developing a balanced PFAS strategy. EPA should leverage its previous work on the first Trump Administration's PFAS Action Plan to engage across the U.S. government, the states, the private sector, and academia to develop a comprehensive plan. The Biden EPA pushed forward regulations that were neither based in sound science, nor appropriately reflective of EPA's crucial previous work on the PFAS Action Plan. This resulted in many legally and factually problematic rules that have made it challenging to manufacture essential products in the U.S. We suggest utilizing the interagency PFAS 1 https://www.uschamber.com/environment/business-coalition-on-pfas-principles-policyrecommendations 1 Sierra Club FOIA 2025-EPA-08249 ED_019467A_00000255-00001 SC_EVERSPLIT0030513 task force and water subcabinet as important mechanisms to bring together all relevant federal agencies for this key discussion. The high-level priorities that the agency released offer an important first step. Champion and fix important underlying science processes at the agency. EPA has gotten away from robust, peer reviewed, and balanced science to support its regulatory actions, especially related to PFAS. The agency must fix the flawed science-related processes at the root of current PFAS rules issued by the previous Administration, including the national primary drinking water standard, and must update them utilizing the best available science and risk management. We welcome the reconstitution of the Science Advisory Board and urge addressing the flawed science of the Integrated Risk Information System (IRIS) program as well. Engage in an ongoing national dialogue around essential chemistries and the lack of viable alternatives. PFAS chemistries, particularly fluoropolymers and f-gases, are so important that the U.S. Chamber of Commerce published an ,xtensive study' on the impacts to the economy should PFAS be banned from use. These essential industries include aerospace, data centers, energy, health care, mobility, and semiconductors. The report underscored the significant threat to GDP, jobs, and tax revenue should access to essential chemistries be limited. More engagement is needed with all relevant stakeholders on the policy approaches to support these important issues. As you and your colleagues well know, it is vital to understand that all PFAS are not the same. Depending on the definition, the category of PFAS could include upwards of 10,000 different substances. They can have significantly different exposure and hazard profiles, and some are indispensable in many vital industries as they offer unmatched strength, durability and reliability as well as chemical resistance and thermal stability, while generally being considered safe. Lumping them all together in a one-size-fits-all approach does not speak to the degree of risk posed by a specific PFAS nor its essential uses and benefits. We believe there is a logical path forward that will enable the United States to continue the manufacture, import, and essential uses of PFAS chemistries, while also being the global leader in the protection of human health and the environment. We stand ready to work with EPA on all these matters and look forward to supporting the use of sound science to inform renewed, reformed decision-making processes for EPA as it addresses these critical issues. 2 https://www.uschamber.com/environment/essential-chemistries-providing-benefits-across-the-u-seconomy 2 Sierra Club FOIA 2025-EPA-08249 ED_019467A_00000255-00002 SC_EVERSPLIT0030514 We appreciate your attention to begin this important policy work. Sincerely, Alliance for Automotive Innovation Alliance for Chemical Distribution American Chemistry Council American Coatings Association American Fuel & Petrochemical Manufacturers American Petroleum Institute Communications Cable & Connectivity Association Cookware Sustainability Alliance Council of Industrial Boiler Owners Fluid Sealing Association Fuel Cell & Hydrogen Energy Association International Association of Plumbing and Mechanical Officials National Asphalt Pavement Association National Association of Manufacturers National Association for Surface Finishing National Council of Textile Organizations National Mining Association Printing United Alliance SEMI TRSA -- The Linen, Uniform and Facility Services Association U.S. Chamber of Commerce Value Manufacturers Association of America Cc: Jessica Kramer, Senior Advisor Peggy Browne, Acting Assistant Administrator, Office of Water 3 Sierra Club FOIA 2025-EPA-08249 ED_019467A_00000255-00003 SC_EVERSPLIT0030515