Failure To Quantify Benefits, Costs Leaves Key EPA Rules Legally Vulnerable

EPA’s inability to fully quantify the costs and benefits of regulations mitigating the harmful effects of per- and polyfluoroalkyl substances (PFAS), tightening facility risk management and governing air emissions threatens to undermine the rules’ legal basis, as industry groups seek ways to scrap or dilute the rules in likely litigation. In one recent example, industry groups claim EPA has failed to properly account for the full costs and benefits of its proposal to list the two most common PFAS, perfluorooctanoic...