Advance Your PFAS Compliance Plan as Expectations Evolve

Julie Huerta

Regulatory Compliance Specialist

Koby Boman

Water/Wastewater Treatment Engineer

Protecting communities’ drinking water from PFAS contaminants is requiring water utilities to prepare for new federal standards while staying flexible as guidance from the Environmental Protection Agency evolves.

Utilities can strike the right balance, even with uncertainties, by taking several key steps:

• Undertake additional monitoring for confidence in your PFAS results.
• Develop a Compliance Plan to outline your options, funding sources and steps for pivoting if results or regulatory expectations change.
• Prepare communications with all your stakeholders: customers, regulators and partner organizations.

Why “act now” — instead of “wait and see”?

The path to addressing PFAS is dotted with uncertainties: new and sensitive sampling methods; limited existing data for many water systems; questions about compliance timelines; and possible changes to regulated contaminants and their limits.

But utilities face multiple pressing factors:

• Increased concerns about PFAS dangers to public health underscore a need for systems to determine their contaminant levels and take action if PFAS are detected.
• More public attention on PFAS means customers are asking questions. To maintain trust, utilities should demonstrate how they are responding to protect public health.
• Many states are considering PFAS regulations for both water and wastewater beyond the EPA’s revised proposal.
• Even if a previously announced federal PFAS compliance deadline is delayed as proposed, installing treatment systems can take 5-6 years of planning, design and implementation.

Where do the rules stand?

The EPA announced in May 2025 that it will reevaluate some of the previously set Maximum Contaminant Limits (MCLs) for PFAS and delay the compliance deadline to 2031. This will give water systems additional time to plan and implement treatment solutions. As part of this initiative, the EPA said they plan to issue a proposed rule in fall 2025 and finalize it in spring 2026. Meanwhile, the PFAS rule is being challenged in court. But even a longer compliance window doesn’t leave much time to prepare. Mapping out flexible, data-driven strategies can keep utilities ahead of regulatory shifts while protecting public health and managing resources.

What should a PFAS Compliance Plan contain?

Current Regulatory Guidance Materials: Develop clear materials that summarize both EPA and state-level requirements as they relate to your utility. Incorporate key deadlines for monitoring and compliance.

A Strategy Based on Your Conditions: Outline your options for addressing PFAS and visualize the pathway to compliance if PFAS are detected now or if results change in the future. Identify treatment options, alternative raw water supplies and available funding sources.

Trustworthy Monitoring: Line up an established monitoring program and define a pre-regulatory (baseline) monitoring program and Quality Control procedures. Accurate, representative sampling and results will provide confidence and guide actions needed for compliance.

Public Communications Tools: The new federal limits include public communication requirements. You can build trust now by proactively sharing clear, accessible information and educational resources about PFAS on your utility website.

An Action Plan: A step-by-step roadmap should define triggers for decision-making and tie them to specific actions.

No matter what your situation is, planning ahead and taking these steps will help you prepare or improve your posture to meet PFAS compliance on time.

How Freese and Nichols Can Help

With our team’s expertise and experience in environmental science and water treatment, we can assist you with all aspects of PFAS regulatory compliance.

To learn more, contact David Jackson, david.jackson@freese.com; Viraj deSilva, viraj.desilva@freese.com; Koby Boman, koby.boman@freese.com; or Julie Huerta, julie.huerta@freese.com.

Julie Huerta directs Freese and Nichols’ program to help clients meet new federal drinking water standards. She is based in Houston, Texas.

Koby Boman, PE, is a Water/Wastewater Treatment Engineer focusing on regulatory compliance, based in Houston.