This RIA estimates total annual notification costs by multiplying the estimated annual number of PFOA and PFOS notifications nationally by the estimated cost of notification per site. Exhibit 3-3 summarizes the range of total annual notification. As the exhibit shows, annual notification costs are an estimated $0 to $370,000.
                                  Exhibit 3-3
         Estimated Total Annual Notification Costs (adjusted to 2020$)
           Estimated Annual Number of Notification in United States
                     Estimated Notification Costs (Total)
                                    0 - 660
                                 $0 - $370,000
3.1.4  Costs Associated with the Hazardous Materials Transportation Act (HMTA)
 Potential direct costs may result from the DOT requirement to list and regulate CERCLA designated hazardous substances as hazardous materials under the Hazardous Materials Transportation Act (see CERCLA Section 306(a)). EPA estimates these incremental costs as zero or negligible. It is unlikely that regulated entities would ship PFOA or PFOS in quantities equal to or above the RQ because use and production of these chemicals are understood to have been largely phased out of production and use beginning in 2000 thus the incremental shipping costs are not expected to be significant. Rather, it is expected that residual quantities shipped would be commingled with other hazardous materials that are already handled and shipped as hazardous materials under the Hazardous Materials Transportation Act.
3.2  Unquantified Direct Costs
 The proposed rule will also create additional costs associated with CERCLA section 120(h) requirements for
 federal agencies to provide notice of the release of hazardous substances when selling or transferring federally-owned real property. In addition to providing notice at the time of sale, in previous sales transactions federal agencies have been required, in certain circumstances, provide a covenant warranting that "all remedial action necessary to protect human health and the environment with respect to any [hazardous substances] remaining on the property has been taken before the date of such transfer, and any additional remedial action found to be necessary after the date of such transfer shall be conducted by the United States."
 The number and magnitude of future federal property sales and transfers involving property contaminated with PFOA and/or PFOS is highly uncertain. Due to this uncertainty, this analysis does not attempt to quantify these costs. EPA requests comment on the number of properties that were previously transferred out of federal control with a deed that includes a covenant to provide remedial action.
3.3  Qualitative Description of Benefits
Qualitative benefits of this action include improved quality of information and a more comprehensive understanding of the number and location of sites with future releases of PFOA and PFOS which meet or exceed the RQ. This information on releases of PFOA and PFOS will enable more efficient decisions in the marketplace for nearby properties. Individuals who are more risk averse may prefer to locate farther away from sites with reported PFOA or PFOS releases relative to people who are less risk averse.
Increased data disclosure regarding individual companies' releases may also reduce uncertainty in capital markets. The value of this reduced uncertainty may be reflected in the market capitalization or cost of capital of affected firms. These changes represent a benefit to society because they allow financial capital to be allocated more efficiently than under baseline conditions, thereby expanding the productive capacity of the economy. For example, a study by Campbell et al. analyzes the relationship between environmental liability uncertainty, specifically Superfund liabilities, and a firm's market valuation (market value of common stock). Focusing on the chemical, paper, and machinery industries, Campbell et al. found that significant uncertainty in a firm's Superfund liabilities could reduce its market value by more than $4 per share per site in the sample, though this result varied significantly across industries.
Other direct benefits associated with the proposed rule's reporting requirements could include better waste management practices for facilities handling PFOA or PFOS in an effort to avoid releases of these substances into the environment. Incentivizing the prevention of releases is expected to decrease potential threats to public health and welfare and the environment. Several studies have shown that increased transparency regarding environmental releases is associated with reductions in releases. Focusing on toxics releases that became subject to disclosure following passage of the Emergency Planning and Community Right to Know Act in 1986, Konar and Cohen found that firms with the largest decline in stock price following disclosures of their environmental releases through the Toxics Release Inventory (TRI) reduced their releases more than their industry peers. Similarly, and also focused on TRI, a subsequent study by Konar and Cohen found that disclosure requirements led to the most significant reductions in releases among firms that were most visible to the public. Examining repeated public disclosures of releases by firms in the chemical industry between 1990 and 1994, Khanna et al. concluded that repeated provision of release data led to reductions in stock price, which then had a significant negative impact on subsequent toxic releases from these sites.
Requiring that releases of PFOA and PFOS be reported may improve the speed and design of any subsequent cleanups (both privately and publicly funded), thereby potentially reducing risks and conferring benefits earlier. For example, the reporting of a release could potentially raise community awareness of a release and accelerate a privately-financed voluntary cleanup. This could more quickly reduce risks faced by nearby exposed individuals.
These actions are discretionary and dependent on various factors that are challenging to predict, but, depending on local site conditions and technology options, may include averting actions or requirements for remediation.
3.4  Qualitative Discussion of Indirect Costs, Benefits, and Transfers
 The proposed designation of PFOA and PFOS as CERCLA hazardous substances may lead to benefits and costs from potential indirect impacts on assessment and response activities. Transfers of costs from the public to responsible parties may also occur contingent upon statutory requirements being met, and discretionary actions by EPA. Consistent with the guidance of Office of Management and Budget's (OMB's) Circular A-4, further economic considerations are included to provide the public with insights related to indirect costs, benefits, and potential transfers of liability.
3.4.1  Indirect Costs including Cost Savings
To the extent that the Proposed Rule shifts the response burden from EPA to potentially responsible parties (PRPs) in the private sector, response and clean-up may be less costly than under baseline conditions. When CERCLA was passed, one of the reasons for establishing a hybrid system in which PRPs themselves implement many cleanups was to harness the efficiency and expertise of the private sector.  If the private sector is able to complete cleanups for sites contaminated with PFOS or PFOA more efficiently than the public sector, the costs of site clean-up may decline relative to baseline.
In addition to the potential for notification requirements of releases of PFOA and PFOS to NRC to improve the speed of response actions (both privately and publicly funded), EPA's improved authority to transfer response costs to PRPs may also enable more efficient response to PFOA and PFOS than under baseline authority to respond to PFOA and PFOS as pollutants and contaminants. Earlier response activity is generally considered to be more cost efficient, in that containing and removing more concentrated contamination is more cost efficient than addressing contamination that over time has spread to a greater area.  For instance, it may be more cost effective to respond to one highly contaminated property before contamination spreads than multiple properties with lower contamination levels that resulted from migration of an earlier contamination event.  PFOA and PFOS are both known to be mobile and persistent chemicals in the environment and contaminated soil has been shown to result in groundwater plumes that grow in size over time. More prompt cleanup is also likely to reduce response costs associated with providing alternate drinking water supplies because fewer households will be in need.
At least partially offsetting these cost savings, earlier response activity (all else equal) will increase the costs of clean-up in present value terms. Whether the net impact of earlier response is an increase or decrease in costs is uncertain and will depend on the relative magnitude of these competing effects.
The rule may also result in increased research and development (R&D) expenditures to ensure the effective removal of PFOA and PFOS. The need for these R&D expenditures is unclear, however. For example, it is uncertain how those wastewater treatment plants needing to treat high levels of PFOA and PFOS would remove them from wastewater treatment sludge. Depending on whether incineration (an existing technology) is effective for the removal of PFOA and PFOS from wastewater treatment sludge without creating harmful products of incomplete combustion, additional R&D expenditures may or may not be necessary to ensure effective removal. R&D costs have been included in past EPA RIAs. For example, the RIA for the 2017-2025 light-duty vehicle greenhouse gas emission standards and corporate average fuel economy standards estimated R&D costs through the use of indirect cost multipliers. EPA requests comment on the R&D expenditures that may be necessary to ensure effective removal of PFOA and PFOS.
Another potential indirect impact of this proposed designation may include an impact on the number of sites identified, assessed, and/or remediated. However, the incremental change in the total number of such sites is unknown due to a lack of data. Therefore, it is not feasible to quantify the associated costs. See Section 3.7 for discussion about the nature of indirect costs and Section 3.8 for a description of uncertainties and analytic limitations.
3.4.2  Indirect Benefits
Requiring notification of releases of PFOA and PFOS to NRC may improve the speed of subsequent response actions (both privately and publicly funded), thereby reducing risks and conferring health and other social benefits earlier. For example, the reporting of a release could raise community awareness of a release and accelerate a privately-financed voluntary cleanup. This may reduce risks faced by nearby exposed individuals more quickly.
EPA expects that response actions would occur more rapidly than under the baseline situation. Under the baseline, a determination that the detected levels of PFOA and/or PFOS may present imminent and substantial danger would be required along with the commitment of government funding to pay for response. Responding to contaminated sites sooner lessens environmental exposures over time and thereby reduces the cumulative impacts on human health and the environment.
The proposed designation may also lead to an incremental increase in the number of contaminated sites identified, assessed, and remediated. Thus, in addition to an indirect potential effect of speedier cleanups, benefits may be experienced due to additional sites being addressed.
The benefits of reduced PFAS exposure vary, but research has shown that exposure to PFOA and PFOS may lead to the following adverse health effects: high cholesterol, changes in increased liver enzymes, decreased immune response to vaccination, thyroid disorders, pregnancy-induced hypertension and preeclampsia, and cancer. Exposure to PFOA may also lead to fetal growth restriction (reduced birth weight). A more detailed discussion of the health effects associated with PFOA and PFOS exposure is included in the Preamble of the Notice of Proposed Rulemaking. Speedier identification, assessment, and response activities addressing PFOA and PFOS exposures are expected to reduce the associated health effects on nearby populations.  The nature of response actions that may induce the described indirect benefits are dependent on various factors that are challenging to predict, but, depending on local site conditions and technology options, may include averting actions or requirements for response. CERCLA cleanups are conducted when site-specific risk assessments identify potential environmental or human health risks. To the extent that the proposed designation reduces the risks of these adverse health effects, this will lead to a health care cost savings.
The health benefits related to reduced exposure to PFOA and PFOS may be realized by multiple segments of the population. To the extent that individuals who realize these benefits participate in the labor force, the reduction in exposure to PFOA and PFOS would potentially lead to improvements in worker productivity. In general, the number of sick days among workers who are healthy is lower than the number of sick days among workers who are not healthy. While at work, healthier employees are generally more productive. Thus, pollution reduction at sites affected by PFOA or PFOS where people are exposed is likely to improve productivity for those exposed individuals who are work force participants. A small but growing literature addresses the relationship between air pollution and worker productivity.
As described in Section 3.6.1, the proposed rule may result in R&D expenditures to develop more effective removal methods for PFOA and PFOS. A potential benefit of these expenditures is that removal may become more efficient. The need for R&D and subsequent magnitude of related benefits, however, are uncertain. EPA requests comment on any R&D-related benefits that may result from the Proposed Rule.
In addition to the indirect benefits described above, the clarification of reporting responsibilities, and earlier responses to contamination, could indirectly contribute to more efficient litigation (e.g., by reducing public entities burden of proof requirements related to contamination). To the extent that this occurs, funds that would have been used for related litigation can be redirected to expand or improve other publicly funded goods and services.

3.4.3  Transfers
T
his proposed rulemaking is one step towards potential PFOA and PFOS response cost recovery for EPA, and allows EPA to respond to PFOA and PFOS contamination without making a potential imminent and substantial danger finding. However, the proposed designation does not require EPA to take response actions, does not require any site-specific response action by a private party, and does not determine liability for hazardous substance release response costs. In the baseline, if EPA sought to initiate a response action, the Agency could use its authority under CERCLA section 104(a) for pollutants and contaminants if a release or threatened release may present an imminent and substantial danger to the public health or welfare. When the EPA responds to a release or threat of a release of a pollutant and contaminant under Section 104, the US Government (i.e., the taxpayer) incurs the costs and does not have the authority to recover those costs from responsible parties. This is because the costs of response to address a substance under CERCLA Section 107 are only recoverable if the substance is a "hazardous substance." The proposed rule would designate PFOA and PFOS as hazardous substances under Section 102, which would enable EPA to recover its costs of response from responsible parties  -  i.e., transfer the cost of its response from the taxpayer to a liable party. Thus, an important indirect impact of the proposed designation is to transfer the costs of potential response activities from the public to polluters. The potential in some instances to affect liability in a way that would transfer response costs from taxpayers to polluters is not considered a cost (either direct or indirect) resulting from the proposed rule. A qualitative discussion of the nature of potential transfers associated with future discretionary response decisions is presented below (see Section 3.6.4)
In addition to having the capability in the baseline to address PFOA and PFOS with a potential imminent and substantial danger finding, there is another important circumstance when PFOA and PFOS contamination can be addressed in the baseline. To the extent PFOA or PFOS are commingled with releases of hazardous substances at facilities, EPA and other agencies exercising delegated CERCLA authority may require the responsible party to address such releases.
If this proposed designation is finalized, a broader range of response authority could be applied. EPA and other agencies exercising delegated CERCLA authority, may respond to these PFOA or PFOS without making a finding that the substances may present imminent and substantial danger, may require the responsible party to address a release, and may seek contribution or recovery of costs incurred for their response actions, contingent on other relevant statutory criteria being met. The above actions are considered transfers and may apply to releases that occurred prior to finalizing the Proposed Rule as well as after promulgation of a Final Rule.
3.5 Uncertainties Regarding Indirect Impacts on Response Activities
Significant uncertainty about the extent of existing PFOA and PFOS use and contamination, evolving assessment and response technologies, and health science pose outstanding barriers to developing a robust quantitative analysis of the indirect costs, benefits, and potential transfers associated with response to PFOA and PFOS contamination under CERCLA. This section describes some of those uncertainties in detail and provides further insight into the analytical limitations preventing quantitative analysis. EPA requests comment on uncertainties regarding the unquantifiability of indirect cost, benefit, and transfer impacts as described below.
 EPA is not aware of any peer reviewed literature on systematic examination of liability, management, and cleanup costs associated with PFOA and PFOS contamination. There are several peer-reviewed journal articles providing perspectives on this topic.[,]  However, none of the articles that EPA is aware of provide quantitative data expressly for PFOA and PFOS, but rather provide insight about possible costs of liability, management, and cleanup associated with PFAS, defined in each article as a class of over 9,000 chemicals.  These articles do not provide information about costs specific to distinct response activities, the number of sites for testing and remediation, the level of remediation, types and/or quantities of environmental media considered for remediation, or other details that would be useful in conducting robust quantitative cost and benefit analysis. In addition, these works do not provide enough information on regulatory structure to inform attribution of costs.  Attribution of costs is an important consideration due to ongoing work at State and Federal levels. Given the lack of information and systemic analysis of remediation of PFOS and PFOA, we seek information and comment that may allow EPA to estimate incremental indirect costs associated with this rule.
 While data specific to PFOA and PFOS remediation are limited, a 2019 EPA Market Study provides some context for remediation costs associated with other hazardous substances at non-federal NPL sites. The NPL is the list of sites of national priority among the known releases or threatened releases of hazardous substances, pollutants, or contaminants throughout the United States and its territories. The NPL is intended primarily to guide the EPA in determining which sites warrant further investigation. Based on the 2019 study, historical average total site costs to address all hazardous substances across all sites on the NPL (inclusive of all contamination types and sources) equals between $35.2 and $48.2 million per site These costs are provided for reference, and it is unknown how they would relate or compare to costs associated with response actions addressing PFOA and PFOS at a contaminated site.  For instance, PFOA and PFOS present at a site with other hazardous substances may be addressed with treatment methods used for other hazardous substances, in which case addressing PFOA and PFOS risks would not result in additional response costs above the baseline. Some examples of these treatment methods include granular activated carbon (GAC) filtration, incineration, and the removal/landfilling of contaminated media. In instances where PFOA and/or PFOS contamination are at levels that present a risk absent other hazardous substances, examples of costs associated with a response action would be dependent on the extent of contamination, the cleanup level needed to manage the risks associated with the contamination, and the treatment technology available.
3.5.1 Uncertainties Regarding the Number of Potential Sites Indirectly Affected
EPA lacks information on the number of sites that may require response actions to address past PFOA or PFOS releases. Although the entities that have historically used PFOA and PFOS are described in Chapter 2, the specific sites contaminated with these chemicals is unknown. Exhibit 2-1 summarizes users and associated products that, based on historical use, may contain PFOA and PFOS.
Although this EA lacks adequate data to comprehensively identify and assess the number of sites affected by the proposed rule, there are data available that provide insights into EPA's current understanding of the baseline extent of PFOA and PFOS contamination. One source of data resulted from EPA collecting information on the occurrence of PFOA and PFOS at National Priorities List (NPL) sites.  A total of 175 sites recorded both PFOA and PFOS detection, 3 sites recorded only PFOS detection, and 6 sites recorded only PFOA detection. It is important to note that this list is a preliminary indicator of potential contamination and the existence of a PFOA or PFOS detection at a site is the first in a series of subsequent, contingent steps from a determination that a response action may be necessary to address the chemicals.
Additionally, the use of Aqueous Film-Forming Foam Concentrates (AFFF) at airports is a potential source of site contamination. The National Plan of Integrated Airport Systems (NPIAS) public facing dataset presented by the Federal Aviation Administration (FAA) estimates that there are 3,314 airports across the US; it is unknown how many of these airports have experienced AFFF releases. Using SEMS data, 48 NPL sites with a PFAS detection are located at airports, though the majority of these sites are located at military installations and may not be representative of operations at commercial airports.
The existence of PFOA or PFOS detections or use at a site does not necessarily imply that further evaluation is needed or would result in a determination that a response action is warranted. The universe of sites that have PFOA or PFOS contamination that warrants response action under CERCLA is indeterminable due to lack of site-specific information and standards for cleanup.
3.5.2 Uncertainties Regarding Cleanup Standards
Exhibits 2-2 and 2-3 provide examples of state and residential standards used to evaluate PFOA and PFOS levels in water and soil, and additional scientific reviews that may inform future standards. To date, site remediation has been focused on sites of specific concern to various states and localities, with varying cleanup objectives. Associated costs may therefore reflect fluctuating levels of concern or types of sources; specific-site remediation activity may or may not be representative of potential sites, in scope or cost, indirectly affected by the proposed rule. The lack of data about the number and types of sites requiring assessment and the specific costs associated with required assessments and response activities prevents quantitative assessment of response costs.
There is significant uncertainty surrounding additional and future impacts associated with development of/changes in federal cleanup standards to reflect changes to toxicity values for PFOA and PFOS. Absent a change in reportable quantities, these would not affect the direct costs of the Proposed Rule or the sites affected by the Proposed Rule, but they would ultimately affect indirect response costs, benefits, and potential transfers. The associated impacts resulting from developments and/or changes in federal cleanup standards are noted here for awareness but would be attributable to those subsequent rulemakings specifying such standards.
                    Appropriate site remedies and associated costs, benefits, and transfers are determined in part by the response standards in place.  As these emerge and evolve at the federal level, anticipated remedies and costs may change. Moreover, current state requirements vary and may change, affecting the selection of technologies.
                    The number and type of sites and environmental media requiring response action might also be affected as cleanup standards emerge at both the federal and state level.
3.5.3 Uncertainties Regarding Assessment and Cleanup Technologies and Associated Costs
The evolving understanding of technology used to assess and respond to various PFOA- or PFOS-contaminated media at sites introduces further uncertainty in developing a quantitative estimate of the cost of response actions associated with the designation of PFOA and PFOS as hazardous substances under CERCLA section 102(a). Treatment and disposal technologies for PFOA and PFOS are changing, and the associated costs of implementing these technologies vary significantly based on geographic location, partly due to transportation costs and access to treatment and disposal facilities.
Numerous research efforts on PFOA and PFOS dedicated to risk assessment methods and advancing remediation technology options are underway and new information is regularly made available in this regard. Examples of such efforts include the following: Department of Defense environmental research programs include the Strategic Environmental Research and Development Program (SERDP) and the Environment Security Technology Certification Program (ESTCP). These programs have sponsored research on addressing PFAS contamination and information about the research is available on their website.  EPA's Office of Research and Development has conducted and sponsored a number of studies to advance the understanding of PFAS treatment, disposal, toxicity, and environmental fate and transport and much of this research is ongoing. In addition, the Contaminated Site Cleanup Information Web Site (CLU-IN.org) publishes information about advances in technology across the hazardous waste remediation community, including developments in treatment options for PFAS.
Finally, the incremental cost of addressing PFOA and PFOS relative to baseline costs of treating other contaminants on existing contaminated sites is unknown. PFOA and PFOS present at a site with other hazardous substances may be addressed with treatment methods used for other hazardous substances, in which case addressing PFOA and PFOS risks would not result in additional response costs above the baseline.
3.5.4 Summary of the Process and Associated Costs for Determining Response Efforts
The following information provides an overview of the process of determining whether response may be warranted at a site, and the associated methods that might be employed if a need is identified:
 Sampling. For sites on the NPL, EPA may take samples to determine whether a PFOA and/or PFOS release requires additional investigation or action.
 Additional investigations and feasibility studies. Once media have been sampled, additional data are gathered at the site. A feasibility study is also conducted that develops and evaluates options for remedial actions.
 Remediation efforts. A remedial design plan is developed to address contaminated media. Contaminated soil is removed, treated, and/or disposed. Contaminated groundwater is pumped and/or treated; successful water treatment technologies include activated carbon adsorption, ion exchange resins, and high-pressure membranes. Water cleanup activities can also include installing water treatment facilities, providing alternative drinking water, shutting down drinking water wells, and connecting homes with private wells to municipal water systems.
With regard to the potential for new sites to be added to the NPL due to PFOA or PFOS contamination, before EPA adds a new site to the NPL, the site must meet EPA's requirements and be proposed for addition to the list in the Federal Register, subject to a 60-day public comment period. Response actions, which include investigations of releases of hazardous substances and determining if removal or remedial action is necessary, are contingent, discretionary, and site-specific. EPA prioritizes the highest-risk sites under CERCLA (and that listing process is open to public comment); the process for selecting remedies includes public notice and comment; and cost considerations, among other important factors such as protectiveness, are part of CERCLA's site-specific cleanup approach. The associated impacts resulting from newly added sites to the NPL are noted here for awareness but would be attributable to those subsequent final rulemakings listing individual sites.
The Department of Defense (DOD) has also released cost estimates associated with PFAS response efforts at military sites, not specific to PFOA or PFOS.[,] It is important to note that these estimates represent one cost point for potential PFAS response costs specifically focused on applications related to national defense. It is possible the PFAS costs released by DOD are not representative of other sites as the types, quantity, and handling of PFAS are expected to vary greatly. An equally important consideration to note associated with DOD cost estimates is that the EPA expects the size and scope of, and therefore costs associated with, federal PFOA or PFOS cleanup sites to be substantially larger than non-federal sites.
 DOD reports that it has incurred $1.1 billion in investigation and cleanup costs for PFAS through fiscal year 2020; future remediation costs, or costs after fiscal year 2020, will exceed $2.1 billion.  As of 2020, DOD has identified 687 sites with a known or suspected release, including 328 Army installations, 149 Navy installations, 203 Air Force installations, and seven Defense Logistics Agency installations. DOD provides an additional breakdown of its annual obligations between fiscal years 2018 and 2021 in its 2021 Report to Congress:
     DoD obligated $204.5 million to investigate and $124.3 million to clean up PFAS through the end of FY 2018. DoD obligated an additional $51.9 million for investigations and $120.8 million for cleanup of PFAS in FY 2019. In FY 2020, DoD planned to obligate $70.8 million and $40.6 million to investigate and clean up PFAS, respectively; DoD's actual obligations were $242.5 million and $28.3 million, respectively. DoD plans to obligate $56.4 million to investigate and $39.9 million to clean up PFAS in FY 2021. After FY 2021, DoD estimates that it will obligate $442.8 million to investigate and $318.1 million to clean up PFAS. The appendix provides these obligations by DoD Component and installation.
     DoD does not track funding by contaminant and, as such, the data presented in the appendix represents the DoD Components' best estimates of the funding obligated and to be obligated for investigations and cleanup of DoD releases of PFAS. The planned obligations are as of the end of FY 2020 and may change based on the FY 2021 Appropriations Act. Additionally, based on current information, DoD estimates obligations for beyond FY2021 to exceed $1 billion for active installations and National Guard locations as reported here, for a total of $2.1 billion including Base Realignment and Closure sites. DoD expects this estimate to increase as the DoD Components complete the initial assessments and additional information is known about the extent of the cleanup required. The DoD Components will plan and program for these requirements as they are defined.
Estimates of DoD cost obligations to date are both imperfect and partial, as noted by DoD, and it is not clear whether spending for a site is proportional to the extent of contamination or risk. To date, 64 percent of DoD's investigation and cleanup cost obligations are allocated to sites operated by the Air Force or the Air National Guard, suggesting that one of DoD's areas of focus has been on aviation applications.
3.5.5 Summary of Critical Uncertainties Regarding Indirect Impacts on Response Activities
Some of the key critical uncertainties affecting the feasibility of generating quantitative estimates of costs, benefits, and potential transfers associated with response actions for PFOA and PFOS contamination, and more specifically, the indirect impact of the Proposed Rule, if any, on assessment and response activities are provided here.  These include:
 Limited data from PRPs and EPA specifically documenting the incremental costs and benefits of PFOA and PFOS cleanup.
 EPA does not know each of the sites contaminated by PFOA and/or PFOS.
 EPA does not have record of the cost of assessment and cleanup at sites contaminated by PFOA and/or PFOS. Thus, there is no estimate of the magnitude of costs and benefits associated with response actions.
 Limited data are available from PRPs and EPA specifically documenting the incremental cost of PFOA and PFOS cleanup when other hazardous substances are also present. The extent to which PFOA and PFOS contamination co-occur with other substances complicates cost estimates in several ways, including:
 Incremental costs for assessing the extent of PFOA and PFOS contamination are not well documented or specified to date, but may be limited or reduced in context with multiple pollutants.
 Response costs related to PFOA and PFOS may also be affected by other contaminants. For example, treatment for other hazardous substances comingled with PFOA and PFOS may be effective at responding to PFOA and PFOS. Alternatively, consideration of PFOA and PFOS in combination with other contaminants may result in selection of different response methods to optimize site-wide cost effectiveness. Data are not readily available to quantitatively assess these impacts at a level beyond anecdotal examples.

CHAPTER 4.  ECONOMIC IMPACTS ANALYSES RESPONSIVE TO STATUTORY AND EXECUTIVE ORDERS
As required by applicable statutes and executive orders, this chapter summarizes our analysis of equity considerations and other regulatory concerns associated with the proposed rule. This chapter assess potential impacts, with respect to the following issues:
Energy impact: considers the potential for this proposed rule to affect the supply, distribution, or use of energy, including changes in the price of fuel.
Regulatory flexibility: considers the potential for rule-related costs to have a significant impact on a substantial number of small entities (SISNOSE).
Minority and low-income populations: considers the potential for the proposed rule to have disproportionate impacts on minority or low-income populations.
Children's health: considers the potential for the proposed rule to have a significant or disproportionate impact on the health of children.
Regulatory planning and review: requires examination and quantification of costs and benefits of regulating with and without the proposed rule.
Unfunded mandates: examines the implications of the proposed rule with respect to unfunded mandates imposed on state, local, and tribal governments.
Federalism: considers potential issues related to state sovereignty.
Tribal governments: extends the discussion of federal unfunded mandates to include impacts on Native American tribal governments and their communities.
Employment: considers potential impacts on employment resulting from the compliance costs associated with reporting.
4.1  Energy Impact Analysis
Executive Order 13211, "Actions Concerning Regulations that Affect Energy Supply, Distribution, or Use" (May 18, 2001), addresses the need for regulators to consider the potential energy impacts of the proposed rule and resulting actions. Under Executive Order 13211, agencies are required to prepare a Statement of Energy Effects when a regulatory action may have significant adverse effects on energy supply, distribution, or use, including impacts on price and foreign supplies. Additionally, the requirements obligate agencies to consider reasonable alternatives to regulatory actions with adverse effects and the impacts that such alternatives might have on energy supply, distribution, or use.
This action is not a "significant energy action" under Executive Order 13211 because it is not related to, or likely to have a significant adverse effect on, the supply, distribution or use of energy.
4.2   Regulatory Flexibility Analysis
The Regulatory Flexibility Act (RFA) as amended by the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA), 5 USC 601 et seq., generally requires EPA to prepare a regulatory flexibility analysis of any rule subject to notice and comment rulemaking requirements under the Administrative Procedure Act or any other statute. This analysis must be completed unless the agency certifies that the rule will not have a significant economic impact on a substantial number of small entities. If a regulation is found to have a significant impact on a substantial number of small entities, further analysis must be performed to determine what can be done to lessen the impact. Small entities include small businesses, small organizations, and small governmental jurisdictions. EPA developed a screening analysis and supplemental analysis consistent with the requirements under RFA.
For purposes of assessing the impacts of this rule on small entities, a small entity is defined as: (1) a small business as defined by the Small Business Administration's (SBA) regulations at 13 CFR Part 121.201; (2) a small governmental jurisdiction that is a government of a city, county, town, school district or special district with a population of less than 50,000; and (3) a small organization that is any not-for-profit enterprise which is independently owned and operated and is not dominant in its field. EPA typically considers costs in excess of one percent and three percent of revenues as indications that the proposed rule may have a significant impact on a given small entity including businesses and governments, and estimates of greater than 20 percent of total small firms or 1,000 total small firms affected as indications that a substantial number of small entities may be affected by the proposed rule. The following sections consider these thresholds.
4.2.1  Associated Cost of Proposed Rule
The explicit reporting requirements associated with designation of PFOA and PFOS as CERCLA hazardous substances include the reporting requirements for episodic releases of hazardous substances found in CERCLA section 103(a), and the reporting requirements under EPCRA section 304. The reporting activities are:
 Telephone notifications to the NRC, SERC (or TERC), and LEPC (or TEPC); and
 Preparation and submission of a written notification report to the SERC (or TERC) and LEPC (or TEPC).
The costs associated with notification under CERCLA and EPCRA are documented in EPA's Information Collection Requests and Supporting Statements for those regulations, which are No. 1049, OMB No. 2050-0046 and No. 1395, OMB No. 2050-0092 respectively. Additionally, this proposed rulemaking considers additional costs related to federal property transfer requirements associated with the alignment of CERCLA designation with other federal regulations. As discussed in previous sections, the latter costs are currently unable to be estimated due to the lack of information about the number and locations of PFOA and PFOS releases meeting or exceeding the reportable quantity (RQ). This analysis assumes that a given facility will experience no more than one such release per year. Exhibit 3-1 above summarizes these per release costs. The total reporting cost for a facility submitting both a telephone and written notification would be roughly $561.
4.2.2  Revenues of Impacted Small Entities
To estimate the annual breakeven costs per facility, the analysis relies on three pieces of information for each industry: (1) average annual revenues per small entity, (2) average number of facilities per small entity, and (3) the target breakeven percentage of costs to revenues (either one percent or three percent) at both the entity and facility level. While regulatory flexibility determinations focus on entity revenues and not single facilities, uncertainty about the facilities potentially affected and the limitations of the breakeven analysis format make it useful to examine the breakeven values at both an entity and facility level, to reflect the possibility that all locations of an entity (e.g., a car wash) could operate in similar ways and report similar releases.
Exhibit 4-1 shows the estimated breakeven costs per small entity (firm or government) and facility, by industry. These results are presented using six-digit NAICS codes. Estimated annual breakeven costs per facility are lowest for Car Washes (NAICS 811192). Estimated breakeven costs are next lowest at Sewage Treatment Facilities (NAICS 221320) with annual costs of $12,395 meeting the one percent revenue threshold, followed by Commercial Printing - except Screen and Books (NAICS 323111) and Other Airport Operations (NAICS 488119) with annual costs meeting the one percent revenue threshold of $21,930 and $22,239, respectively. Estimated annual breakeven costs for all other industries are greater than $25,000 at the one percent revenue threshold.
While EPA did evaluate potential revenue impacts on Sewage Treatment Facilities (NAICS 221320), it did not analyze impacts on small municipal drinking water utilities because these entities were not identified as potential sources of major PFOA or PFOS releases (see Chapter 2 for full discussion of the universe identified for analysis). EPA does not currently have data on the number or extent of potential releases by small governmental entities, and requests comment on the associated impacts to small municipal drinking water utilities from the proposed rule.

                                  Exhibit 4-1
     Breakeven Estimates for Annual Costs per Facility (adjusted to 2020$)
Industry
                          NAICS Code and Description
                     Annual Revenues per Small Entity
[a]
               Average Number of Facilities per Small Entity
[b]
        Breakeven Annual Cost per Entity: 1% Threshold
[c = (1% x a)]
        Breakeven Annual Cost per
Entity: 3% Threshold
[d = (3% x a)]
      Breakeven Annual Cost per Facility: 1% Threshold
[e = (1% x a)/b]
      Breakeven Annual Cost per
Facility: 3% Threshold
[f = (3% x a)/b]
Aviation operations
488119 - Other Airport Operations
                                                                     $2,537,912
                                                                           1.11
                                                                        $25,379
                                                                        $76,137
                                                                        $22,939
                                                                        $68,818
Carpet manufacturers
314110 - Carpet and Rug Mills
                                                                     $8,527,078
                                                                           1.05
                                                                        $85,271
                                                                       $255,812
                                                                       $81,335
                                                                      $244,006
Car washes
811192 - Car Washes
                                                                       $569,439
                                                                           1.07
                                                                        $5,694
                                                                       $17,083
                                                                        $5,313
                                                                       $15,939
Chrome electroplating, anodizing, and etching
332813 - Electroplating, Plating, Polishing, Anodizing, and Coloring
                                                                     $3,194,451
                                                                           1.04
                                                                        $31,945
                                                                        $95,834
                                                                        $30,704
                                                                        $92,111
Coatings, paints, and varnish
325510 - Paint and Coating Manufacturing
                                                                     $8,579,550
                                                                           1.08
                                                                       $85,796
                                                                      $257,387
                                                                        $79,697
                                                                       $239,090
Firefighting foam manufacturers
325998 - All Other Miscellaneous Chemical Product and Preparation Manufacturing
                                                                     $9,615,850
                                                                           1.06
                                                                        $96,159
                                                                       $288,476
                                                                        $91,107
                                                                       $273,322
Landfills
562212 - Solid Waste Landfill
                                                                     $2,732,229
                                                                           1.02
                                                                        $27,322
                                                                        $81,967
                                                                        $26,744
                                                                        $80,231
Medical Devices
339112 - Surgical and Medical Instrument Manufacturing
                                                                    $10,924,915
                                                                           1.05
                                                                       $109,249
                                                                       $327,747
                                                                       $104,317
                                                                       $312,950
Municipal fire departments and firefighting training centers
922160 - Fire Protection
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
Paper mills
322121 - Paper (except Newsprint) Mills
                                                                   $109,190,104
                                                                           1.28
                                                                     $1,091,901
                                                                     $3,275,703
                                                                       $851,896
                                                                     $2,555,688

322130 - Paperboard Mills
                                                                    $53,571,512
                                                                           1.08
                                                                       $535,715
                                                                     $1,607,145
                                                                       $495,518
                                                                     $1,486,553
Petroleum refineries and terminals
324110 - Petroleum Refineries
                                                                   $919,097,728
                                                                           1.16
                                                                     $9,190,977
                                                                    $27,572,932
                                                                     $7,948,953
                                                                    $23,846,860

424710 - Petroleum Bulk Stations and Terminals
                                                                    $54,054,028
                                                                           1.21
                                                                       $540,540
                                                                     $1,621,621
                                                                       $445,151
                                                                     $1,335,452
Pesticides and Insecticides
325320 - Pesticide and Other Agricultural Chemical Manufacturing
                                                                    $25,079,234
                                                                           1.06
                                                                       $250,792
                                                                       $752,377
                                                                       $236,296
                                                                       $708,887
Photographic film manufacturing
325992 - Photographic Film, Paper, Plate, and Chemical Manufacturing
                                                                     $3,410,199
                                                                           1.05
                                                                        $34,102
                                                                       $102,306
                                                                        $32,595
                                                                        $97,784
Polishes, waxes, cleaning products
325612 - Polish and Other Sanitation Good Manufacturing
                                                                     $9,060,815
                                                                           1.04
                                                                        $90,608
                                                                       $271,824
                                                                        $86,932
                                                                       $260,796
Polymer manufacturing
325211 - Plastics Material and Resin Manufacturing
                                                                    $33,570,756
                                                                           1.14
                                                                       $335,708
                                                                     $1,007,123
                                                                       $293,955
                                                                       $881,864
Printing facilities where inks are used in photolithography
323111 - Commercial Printing (except Screen and Books)
                                                                     $2,256,953
                                                                           1.03
                                                                        $22,570
                                                                        $67,709
                                                                        $21,930
                                                                        $65,790

325910 - Printing Ink Manufacturing
                                                                     $7,404,767
                                                                           1.35
                                                                        $74,048
                                                                       $222,143
                                                                        $54,671
                                                                       $164,012
Textile mills (textiles and upholstery)
313210 - Broadwoven Fabric Mills
                                                                     $8,800,871
                                                                           1.04
                                                                        $88,009
                                                                       $264,026
                                                                        $84,396
                                                                       $253,189

313220 - Narrow Fabric Mills and Schiffli Machine Embroidery
                                                                     $4,053,810
                                                                           1.04
                                                                        $40,538
                                                                       $121,614
                                                                        $39,164
                                                                       $117,492

313230 - Nonwoven Fabric Mills
                                                                    $16,383,181
                                                                           1.08
                                                                       $163,832
                                                                       $491,495
                                                                       $151,160
                                                                       $453,479

313240 - Knit Fabric Mills
                                                                     $8,001,426
                                                                           1.01
                                                                        $80,014
                                                                       $240,043
                                                                        $79,434
                                                                       $238,303

313320 - Fabric Coating Mills
                                                                    $12,333,111
                                                                           1.06
                                                                       $123,331
                                                                       $369,993
                                                                       $116,573
                                                                       $349,720
WWTPs
221320 - Sewage Treatment Facilities
                                                                     $1,357,425
                                                                           1.06
                                                                        $13,574
                                                                        $40,723
                                                                        $12,786
                                                                        $38,357
Note: Revenue values obtained from United States Census Bureau's 2017 Statistics of U.S. Businesses (SUSB). Values converted from year 2017 dollars to year 2020 dollars using the GDP Deflator.
Note: EPA did not consider the cost impacts on small government municipal drinking water utilities because they were not identified as potential major sources of PFOA and/or PFOS releases in any of the literature reviewed.

For the sector with the lowest breakeven costs per facility (Car Washes  -  NAICS 811192), the smallest size class reported has a revenue average of $48,496. Even in this class, the per release cost of $561 represents less than three percent of revenues and just slightly more than one percent of revenues. Similarly, for five other industries, the $561 cost per release is slightly more than one percent of revenues for the smallest revenue class among small entities but less than three percent (range of 1.02 percent to 1.08 percent). The annual revenues for these entities range from $51,980 to $55,256. Collectively, these entities represent less than 9 percent of the small entities reflected in Exhibit 4-1. In addition, the $561 cost is likely to overestimate the typical costs realized by these entities on an annual basis, as entities this small are unlikely to have reportable releases each year.  Thus, EPA expects that there would not be a significant impact on a substantial number of small entities.

4.2.3  Resulting Impact of Proposed Rule on Small Entities
It is not clear what number of small entities in any sector would be required to report as a result of the action under consideration by EPA, but even the total per release cost of $561, when compared with the average revenues for single facilities at small entities in key sectors affected by PFAS (Exhibit 4-1 above), does not come close to exceeding one percent of average facility level (or firm-level) small-entity revenues in any sector. As a result, this proposed action is not expected to result in a significant economic impact on a substantial number of small entities, including small government entities, under the RFA.
4.3  Impacts on Minority and Low-Income Populations: Analysis
 4.3.1  Introduction
Executive Order 12898 (59 FR 7629; February 16, 1994), Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, establishes federal executive policy on environmental justice. Its main provision directs federal agencies, to the greatest extent practicable and permitted by law, to make environmental justice part of their mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of their programs, policies, and activities on minority populations and low-income populations in the United States. EPA defines environmental justice as the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. Executive Order 14008 (86 FR 7619; January 27, 2021), Tackling the Climate Crisis at Home and Abroad, also calls on Agencies to make achieving environmental justice part of their missions "by developing programs, policies, and activities to address the disproportionately high and adverse human health, environmental, climate-related and other cumulative impacts on disadvantaged communities, as well as the accompanying economic challenges of such impacts." It also declares a policy "to secure environmental justice and spur economic opportunity for disadvantaged communities that have been historically marginalized and overburdened by pollution and under-investment in housing, transportation, water and wastewater infrastructure and health care." EPA also released its "Technical Guidance for Assessing Environmental Justice in Regulatory Analysis" (U.S. EPA, 2016) to provide recommendations that encourage analysts to conduct the highest quality analysis feasible, recognizing that data limitations, time and resource constraints, and analytic challenges will vary by media and circumstance.
This RIA includes a screening-level analysis of the demographics of the populations in proximity to potential sites in the universe and considers the possible impact of the proposed guidance on populations and locations relevant to Executive Orders 12898 and 14008.
 4.3.2  Demographic Analysis
This demographic analysis examines populations in U.S. Census block groups that intersect with identified site boundaries and designated areas around them (i.e., buffers). Site spatial information can either take the form of polygons identifying the actual site boundaries, or single points designating the location (centroids), depending on the availability of data. Polygons represent the actual mapped boundary of any particular site. Centroids, on the other hand, are point estimates. To estimate the populations living near (or in some cases within) site boundaries when only centroid information is available, the analysis models centric (circular) boundaries meant to approximate site boundaries. These areas are created using certain distances around the centroid; standard distances used to approximate sites and the areas around them for RCRA and NPL site centroids are one and three miles. Similarly, the analysis considers buffers of one and three miles around the site boundaries of polygons.
This proposed regulation identifies groundwater and surface water as potential sources of exposure for the identified PFAS. Because the location of future releases of PFAS is uncertain, this analysis considers populations around facilities in sectors associated with widespread historical uses and releases of PFAS as proxies for facilities that may have future releases of the PFAS considered in the proposed rule. This analysis examines the following site types as proxies for facilities that are known to have commonly used PFAS:
 Operating Department of Defense (DOD) facilities
 Operating U.S. airports and airfields
 Large U.S. airports and airfields
 All other U.S. airports and airfields (i.e., medium and small)
 Plastics material and resin manufacturing firms identified as having produced PFOS and/or PFOA[,]
 2020 PFOS and PFOA releases reported to EPA's Toxic Release Inventory (TRI)
These proxy sites may not capture actual release locations that will require reporting, and they do not reflect all sites where PFAS was used or released, but there is some consistency in the historical use across sites in these sectors. This historical use provides EPA with a reasonable starting point for examining demographic patterns. The assessment of these sites would be informed by information on the prevalence of PFOA and PFOS at these sites, the corresponding risks to local populations, and the benefits of the proposed designation. The development of reliable quantitative or even qualitative ratings of the proxy sites or sectors, however, if not feasible due to a lack of available information. There is uncertainty regarding future releases of PFOA or PFOS  and the risks associated with future releases would depend on site-specific information that is not readily available, such as the likely size of a release at a given site and the exposure level for each site if a release were to occur.
Exhibit 4-2 summarizes several key demographics of the total populations near the universe of proxy sites and compares these demographics to U.S. national averages. The six key demographic categories examined are minority (reflecting an examination of both race and ethnicity; minority is defined as populations excluding non-Hispanic White), poverty level, linguistic isolation, education, age (specifically population less than five years old and greater than 64 years old), and age of housing.

                                  Exhibit 4-2
Proportions of Key Demographics in the Total Near Site Population and the Total U.S. Population
 Demographic Category
Population within 1 or 3 miles of a Plastics Material and Resin Manufacturer and/or a Release Reported to TRI
                 Population within 1 or 3 miles of a DOD site
               Population within 1 or 3 miles of a Large Airport
         Population within 1 or 3 miles of a Small or Medium Airport
U.S. Population

                                    1 mile
                                    3 miles
                                    1 mile
                                    3 miles
                                    1 mile
                                    3 miles
                                    1 mile
                                    3 miles

Race

Asian
                                     6.02%
                                     6.82%
                                     7.93%
                                     7.42%
                                     6.22%
                                     8.16%
                                     3.73%
                                     4.34%
                                     5.39%
Black/African American
                                    22.58%
                                    23.56%
                                    15.83%
                                    16.34%
                                    14.51%
                                    17.03%
                                     9.04%
                                    10.26%
                                    12.65%
Hawaiian/Pacific Islander
                                     0.06%
                                     0.08%
                                     1.07%
                                     0.55%
                                     0.36%
                                     0.33%
                                     0.19%
                                     0.19%
                                     0.18%
Native American
                                     0.44%
                                     0.36%
                                     0.78%
                                     0.75%
                                     0.71%
                                     0.74%
                                     0.91%
                                     0.84%
                                     0.83%
Other
                                     7.80%
                                     7.76%
                                    10.94%
                                    10.73%
                                    11.65%
                                    12.90%
                                     7.23%
                                     7.65%
                                     8.26%
Minority

Minority
                                    48.49%
                                    48.91%
                                    50.94%
                                    50.63%
                                    48.71%
                                    56.70%
                                    32.11%
                                    34.71%
                                    39.56%
Ethnicity

Hispanic (any race)
                                    17.31%
                                    16.06%
                                    21.77%
                                    22.98%
                                    24.38%
                                    28.39%
                                    16.13%
                                    16.97%
                                    18.65%
Poverty Level

Households below the poverty level
                                    18.76%
                                    16.65%
                                    13.80%
                                    14.61%
                                    13.56%
                                    15.31%
                                    12.17%
                                    13.01%
                                    13.70%
Households with a ratio of income to poverty level of two and below
                                    39.95%
                                    36.70%
                                    34.37%
                                    34.58%
                                    62.68%
                                    62.34%
                                    30.73%
                                    31.82%
                                    32.34%
Other Demographics

Linguistically isolated households
                                     4.17%
                                     4.44%
                                     5.32%
                                     6.34%
                                     6.51%
                                     9.16%
                                     3.10%
                                     3.61%
                                     5.08%
Less than a High School Education
                                     9.55%
                                     8.97%
                                     7.58%
                                     8.59%
                                     8.82%
                                    10.76%
                                     8.11%
                                     8.13%
                                     8.44%
Under 5 years of age
                                     6.25%
                                     6.26%
                                     7.20%
                                     6.78%
                                     7.30%
                                     6.82%
                                     6.26%
                                     6.26%
                                     6.13%
Over 64 years of age
                                    12.98%
                                    13.73%
                                    12.08%
                                    13.21%
                                    11.04%
                                    12.55%
                                    15.55%
                                    15.23%
                                    15.29%
Structures Built Pre-1960
                                    53.59%
                                    48.48%
                                    25.71%
                                    29.73%
                                    28.13%
                                    34.50%
                                    21.64%
                                    24.78%
                                    28.01%
Total U.S. Population Captured in Proximity
% of U.S. Population Captured in Proximity
                                     0.15%
                                     1.42%
                                     2.55%
                                    10.08%
                                     0.12%
                                     2.83%
                                     2.57%
                                    23.87%
                                     100%

This initial, high-level assessment suggests that populations within one or three miles of these sites vary based on site type:
 Plastics material and resin manufacturers and/or releases reported to TRI - the average population within one or three miles of a plastics material and resin manufacturer and/or a release reported to TRI has higher rates of households experiencing poverty, older housing stocks, and larger percentages of minority residents than the U.S. averages for these demographics. Specifically, a much higher percentage of Black residents live near plastic material and resin manufacturers reporting to the TRI. The remaining variables are generally similar to (i.e., within +/- 10 percent of) U.S. average populations.
 Operating DOD facilities - the average population within one or three miles of a DOD site has larger percentages of minority residents than the U.S. average, also driven in large part by a notably higher percentage of Black residents. Populations near DOD sites are within +/- five percent of the U.S. average in all other metrics.
 Airports and airfields  -  Because airports across the country vary widely in size, this analysis categorizes them into three general size classes: small, medium, and large. For presentation purposes, this analysis presents large airports separately and groups the remaining two size categories, small and medium. The average population within one or three miles of a small or medium airport is similar to the U.S. average for all demographic variables, reflecting the larger number and geographic distribution of these types of airports and airfields in the U.S. In contrast, populations within one or three miles of a large airport have higher rates of households experiencing poverty and larger percentages of minority residents. The remaining variables are generally similar to (i.e. within +/- 10 percent of) U.S. average populations.
These findings, combined with the uncertainty surrounding the location of future releases, are indicative of potential impacts but do not provide a clear indication of the type of disparities related to potential exposure to PFAS. Consistent with the priorities outlined in Executive Orders 12898 and 14008, it is unclear whether the proposed regulation will have a significant impact on disadvantaged populations or communities with environmental justice (EJ) concerns relative to other communities. While the locations of reporting releases are unknown, to the extent that these proxy locations are representative of likely reporting locations, this screening analysis suggests that the reporting required under the rule may provide better information to nearby populations potentially at risk of exposure, including communities with EJ concerns. To the extent that PFAS releases are consistent with the broader releases reported to TRI and typically involve disposal or manufacturing sites, demographic data around plastics material and resin manufacturer sites and historical releases may be a more reliable predictor of the type of community potentially affected by this proposed rulemaking. Specific site conditions and demographic patterns may become clear as reporting occurs following completion of a final rule.
Although the impact of the findings in this analysis are unclear, published literature supports the conclusion that PFAS reporting can help minority and low-income populations. For instance, reported data from Northeastern University's Social Science Environmental Health Institute published in 2019 show that minority and low-income populations are disproportionately exposed to PFAS as nearly 39,000 more low-income households (15% more than the expected based on U.S. census data) and approximately 295,000 more people of color (22% more than expected) live within 5 miles of a site contaminated with PFAS. In addition, information on the broader links between PFAS exposure and communities with EJ concerns continues to emerge. An August 2021 report the Natural Resources Defense Council examined exposure to PFAS in drinking water in California and found that at least 69 percent of state-identified disadvantaged communities have PFAS contamination in their public water systems, and a number of these communities have levels of PFAS contamination that are higher than average.
As research continues to expand understanding about the distribution of PFAS impacts, it is important to note that this proposed regulation will result in more information about the location and extent of releases. This improved information will not increase exposure risk for communities with EJ concerns and may improve the speed and design of remediation.  Because detection of PFAS contamination in drinking water is linked to the location of industrial facilities handling these chemicals, incentivizing the prevention of releases could benefit communities with EJ concerns near these facilities. EPA is committed to minimizing and/or eliminating existing barriers and burdens that communities with environmental concerns may encounter related to accessing data and information collected as a result of this rulemaking, if finalized. EPA seeks comment on strategies to improve access to the reporting data expected to be collected, if designation of PFOA and PFOS as hazardous substances is finalized, for communities with environmental justice concerns.
 4.3.3  Analytic Limitations
The following methodological assumptions and limitations affect the demographic analysis:
 Due to data limitations regarding the current manufacture and uses of PFAS, this analysis cannot predict where exposures and releases of PFAS are likely to occur. Instead, this analysis uses operating DOD facilities, plastics material and resin manufacturers, releases reported to TRI, and operating airports and airfields (locations with demonstrated historical use of PFAS) to proxy areas with potential PFAS exposures and releases. However, these areas may not reflect actual release locations that would require reporting, and the buffers identified represent only an approximation of the potential risk of exposure to PFAS.   Actual exposure patterns at specific sites could be highly local, variable, or extend past the three-mile buffers (e.g., in water systems).
 The goal of this analysis is to examine the potential demographic impacts of highly local release and exposure patterns of PFOS and PFOA. Because of U.S. Census data limitations, this analysis pulls demographic data across entire census block groups, and may not accurately specific populations affected by a release where those populations vary within block groups.
 Because PFAS exposure through drinking water is understood to be an important route of exposure where sources of drinking water are contaminated, an analysis of drinking water sources and their vulnerability to PFAS contamination would be important to understand potential risks for areas with releases. However, because future release locations are not known, this analysis would not provide additional insight at this time.
 For sites without polygon data, this analysis relies on the use of centroids and one-mile and three-mile centric buffers to replicate site location and surface area, identifying the affected population as the entire population of any U.S. Census block group that falls within the buffer. Many sites in this universe have irregular site areas that do not align with a centroid-based model, and the shape and size of Census block groups varies with population density. This means that this analysis may not capture the specific populations around each site with accuracy, though patterns across a number of sites are likely robust. Specifically, this approach may undercount populations located near sites that are large and/or located in rural areas, where the area of each Census block group is large and centroids are less likely to fall within the buffer.

4.3.4  Supplementary and Sensitivity Analyses
To measure the effectiveness of centroids in characterizing sites that could potentially release PFAS, this RIA examines demographic characteristics for specific sites using EPA's EJSCREEN to validate and expand results to larger areas around sites to better capture populations in rural or other low-density areas (Exhibit 4-4). Of the 15,816 sites examined in the analysis, 4,543 (or 29 percent) did not intersect with a census block group centroid within the three-mile buffer, resulting in a population count of "0" affected. As shown in Exhibit 4-3, the majority of airports that do not intersect with a census block group are characterized as "small". As a result, demographic information around these sites was not factored into average calculations presented in Exhibit 4-2. However, the vast majority of these sites are small airports, which overall are consistent with U.S. average population demographics. The centroid methodology created few empty data points for operating DOD facilities (52), plastics material and resin manufacturers (3), and TRI releases (0). Like Exhibit 4-2, Exhibit 4-3 illustrates the variability of demographic data across site type. On average, airports across the U.S. are surrounded by populations that reflect national averages in relevant demographic categories. Large airports, however, are more likely to be surrounded by minority and low-income populations than medium or small airports. Some DOD sites are surrounded by populations with higher concentrations of minority and low-income residents, but the majority of these sites are below the national averages for these metrics. In contrast, areas around plastics material and resin manufacturer sites and/or sites reporting releases to TRI, on average, are in areas with higher concentrations of minority residents and households experiencing poverty than the U.S. averages for these demographics, suggesting that releases related to manufacturing facilities could have environmental justice implications.

                                  Exhibit 4-3
                      Demographics by Site and Site Type
                                  Site Type
                                  Site Count
                  Do not intersect a Census Block at 3 miles
           Minority Population above the National Average at 3 miles
       Poverty Level (Households) above the National Average at 3 miles

# of Sites
% of Total Site Type
# of Sites
% of Total Site Type
# of Sites
% of Total Site Type
Airport and Airfields
                                                                         14,948
                                                                          4,488
                                                                            30%
                                                                          1,833
                                                                            12%
                                                                          4,014
                                                                            27%
      Large
                                                                            188
                                                                              1
                                                                             1%
                                                                            101
                                                                            53%
                                                                             81
                                                                            43%
      Medium
                                                                            678
                                                                            116
                                                                            17%
                                                                            212
                                                                            31%
                                                                            277
                                                                            41%
      Small
                                                                         14,082
                                                                          4,370
                                                                            31%
                                                                          1,520
                                                                            11%
                                                                          3,656
                                                                            26%
DOD Facilities
                                                                            762
                                                                             52
                                                                             7%
                                                                            312
                                                                            41%
                                                                            329
                                                                            43%
Plastics Material and Resin Manufacturers
                                                                             98
                                                                              3
                                                                             3%
                                                                             46
                                                                            47%
                                                                             50
                                                                            51%
TRI Historical Releases
                                                                              7
                                                                              0
                                                                             0%
                                                                              4
                                                                            56%
                                                                              5
                                                                            71%
Total
                                                                         15,816
                                                                          4,543
                                                                            29%
                                                                          2,195
                                                                            14%
                                                                          4,398
                                                                            28%
As an additional check, this RIA examines four- and five-mile buffers around the 2020 PFOS and PFOA releases reported to TRI using EPA's EJSCREEN tool. In Exhibit 4-4, these results are presented next to the results of the one- and three-mile buffers calculated for this RIA. For these nine sites, the one-mile buffer does not capture populations at three sites, including Cottage Grove, which reported to TRI that PFAS was released for disposal. This information suggests that the one-mile buffer may not accurately capture representative demographic data in surrounding communities for some key sites, such as large manufacturing facilities. The three-mile buffer appears to capture demographics for the community with more accuracy. With the exception of Clean Harbors El Dorado LLC, minority demographics minimally change as site buffers are expanded, confirming that the screening method is generally robust but should not be used for detailed site-specific characterizations. A site-by-site breakdown also presents a more complicated relationship between minority populations and potential PFAS release locations; the standard deviation for minority population around potential release sites is large. Generally, communities around these sites either have large or small minority populations, although most sites have above average minority populations, but more site-specific analysis would be required to fully characterize specific populations. Absent certainty about the locations of future releases, this analysis provides a general indication that releases related to manufacturing sites, in particular, as well as some active military sites, may have implications for communities with environmental justice (EJ) concerns.

                                  Exhibit 4-4
                  Centroids Modeled Around TRI Release Sites
                                     Name
                                    1-mile
                                    3-mile
                                    4-mile
                                    5-mile

Population
Minority
Population
Minority
Population
Minority
Population
Minority
3M Cottage Grove
                                                                              0
                                                                             0%
                                                                         17,011
                                                                            19%
                                                                         30,066
                                                                            16%
                                                                         50,198
                                                                            15%
BASF CORP - Freeport Site
                                                                          1,199
                                                                            67%
                                                                         23,526
                                                                            59%
                                                                         38,980
                                                                            56%
                                                                         56,440
                                                                            54%
Clean Harbors Deer Park LLC
                                                                          8,589
                                                                            89%
                                                                         68,467
                                                                            92%
                                                                        159,187
                                                                            92%
                                                                        275,545
                                                                            91%
Clean Harbors El Dorado LLC
                                                                          1,565
                                                                            77%
                                                                         11,618
                                                                            70%
                                                                         19,042
                                                                            53%
                                                                         21,007
                                                                            51%
Clean Water Environmental LLC
                                                                          3,782
                                                                            66%
                                                                         21,654
                                                                            83%
                                                                         45,707
                                                                            83%
                                                                         77,325
                                                                            78%
Heritage Thermal Services
                                                                          4,130
                                                                            12%
                                                                         18,317
                                                                            10%
                                                                         24,474
                                                                             7%
                                                                         32,046
                                                                             8%
TM Deer Park Services LP
                                                                              0
                                                                             0%
                                                                           6337
                                                                            56%
                                                                         24,665
                                                                            55%
                                                                         63,321
                                                                            55%
Vickery Environmental Inc
                                                                              0
                                                                             0%
                                                                          1,949
                                                                             8%
                                                                          3,088
                                                                             8%
                                                                          9,162
                                                                             9%
Wayne Disposal Inc
                                                                          6,979
                                                                            42%
                                                                         28,971
                                                                            36%
                                                                         41,545
                                                                            34%
                                                                         63,571
                                                                            35%
National Average (TRI Releases)
                                                                         26,244
                                                                            59%
                                                                        197,850
                                                                            62%
                                                                        386,754
                                                                            65%
                                                                        648,615
                                                                            65%

4.4  Impacts on Children's Health Analysis
Executive Order 13045, "Protection of Children from Environmental Health Risks and Safety Risks" (62 FR 19885, April 23, 1997), applies to any rule that: (1) is determined to be "economically significant" as defined under E.O. 12866, and (2) concerns an environmental health or safety risk that EPA has reason to believe may have a disproportionate effect on children. If the regulatory action meets both criteria, the Agency must evaluate the environmental health or safety effects of the planned rule on children and explain why the planned regulation is preferable to other potentially effective and reasonably feasible alternatives considered by the Agency.
EPA's 2021 Policy on Children's Health (October 5, 2021) requires EPA to consider early life exposures and lifelong health consistently and explicitly in all human health decisions. EPA believes that the environmental health or safety risk posed by exposure to PFOA and/or PFOS may have a disproportionate effect on children. Thus, indirect benefits resulting from speedier identification, assessment, and response activities addressing PFOA and PFOS exposures are expected to reduce the associated health effects on nearby populations, including children. To the extent that the proposed designation reduces the risks of these adverse health effects, this will lead to a health care cost savings and a reduction of health risks to children. Discussions of health and risk assessments related to PFOA and PFOS, including developmental and reproductive health effects, are contained in EPA's Health Effects Support Documents for PFOA and PFOS (2016).
4.5  Regulatory Planning and Review
Under Executive Order 12866, "Regulatory Planning and Review" (58 FR 51735, October 4, 1993), EPA, in conjunction with the Office of Management and Budget's (OMB's) Office of Information and Regulatory Affairs (OIRA), must determine whether a regulatory action is "significant" and therefore subject to OMB review and the full requirements of the Executive Order. The Order defines "significant regulatory action" as one that is likely to result in a rule that may:
 Have an annual effect on the economy of $100 million or more or adversely affect in a material way the economy, a sector of the economy, productivity, competition, jobs, the environment, public health or safety, or State, local, or tribal governments or communities;
 Create a serious inconsistency or otherwise interfere with an action taken or planned by another agency;
 Materially alter the budgetary impact of entitlements, grants, user fees, or loan programs or the rights and obligations of recipients thereof; or
 Raise novel legal or policy issues arising out of legal mandates, the President's priorities, or the principles set forth in the Executive Order.
Pursuant to the terms of Executive Order 12866, the Agency has determined that this action is a significant regulatory action that was submitted to the Office of Management and Budget (OMB) for review. The action may raise novel legal or policy issues arising out of legal mandates, the Presidents' priorities, or the principles set forth in the EO. Additionally, while EPA is not considering costs in its hazardous substance designation decisions in this proposed rule, and despite that there is still significant uncertainty and lack of data as discussed in the economic analysis, OMB designated this proposed rulemaking as an economically significant action pursuant to E.O. 12866. Any changes made in response to the OMB recommendations have been documented in the docket. Findings of the regulatory cost analysis (Chapter 3) indicate that the rule, as proposed, is projected to result in aggregate annual social costs of approximately $0 under the lower bound scenario, and approximately $0.37 million under the upper bound scenario.
4.6  Unfunded Mandates Analysis
Signed into law on March 22, 1995, the Unfunded Mandates Reform Act (UMRA) calls on all federal agencies to provide a statement supporting the need to issue any regulation containing an unfunded federal mandate and describing prior consultation with representatives of affected State, local, and tribal governments.
The proposed rule is subject to the requirements of sections 202 and 205 of UMRA. In general, a rule is subject to the requirements of these sections if it contains "Federal mandates" that may result in the expenditure by State, local, and tribal governments, in the aggregate, or by the private sector, of $100 million or more in any one year. To the extent that state, local, or tribal governments are required to report releases under the proposed rule, it represents an unfunded mandate. However, this proposed action is not expected to impose an unfunded mandate of $100 million or more as described in UMRA, 2 U.S.C. 1531 - 1538, and does not significantly or uniquely affect small government entities as analyzed in Section 4.2 above.
4.7  Federalism Analysis
Executive Order 13132, entitled "Federalism" (64 FR 43255, August 10, 1999), requires EPA to develop an accountable process to ensure "meaningful and timely input by state and local officials in the development of regulatory policies that have federalism implications." "Policies that have federalism implications" is defined in the Executive Order to include regulations that have "substantial direct effects on the States, on the relationship between the national government and the States, or on the distribution of power and responsibilities among the various levels of government." EPA typically considers a policy to have federalism implications if it results in the expenditure by State and/or local governments in the aggregate of $25 million or more in any one year.
Under Executive Order 13132, EPA may not issue a regulation that has federalism implications, that imposes substantial direct compliance costs, and that is not required by statute, unless the Federal government provides the funds necessary to pay the direct compliance costs incurred by State and local governments, or EPA consults with State and local officials early in the process of developing the regulation.
This action does not have federalism implications as it will not have substantial direct effects on the States, on the relationship between the national government and the States, or on the distribution of power and responsibilities among the various levels of government.
4.8  Tribal Government Analysis
Executive Order 13175, "Consultation and Coordination with Indian Tribal Governments" (65 FR 67249, November 9, 2000), requires EPA to develop an accountable process to ensure "meaningful and timely input by tribal officials in the development of regulatory policies that have tribal implications."
This proposed action does not have tribal implications as specified in Executive Order 13175. Because the proposed rule is expected to result in minimal costs, EPA does not expect that it would result in any costs or adverse impacts on tribal entities. Thus, Executive Order 13175 does not apply to this rule.
4.9  Employment Impacts
The employment impacts of this action are likely to be minimal and include additional hours for the National Response Center (NRC), State Emergency Response Commissions (SERCs) (or TERCs), and Local Emergency Planning Committees (LEPCs) (or TEPCs) employees who answer the phones and record information regarding releases and those NRC, SERCs (or TERCs), and LEPCs (or TEPCs) employees who input that data into the database. The reporting facilities will require employees to spend time making a release report. However, the per facility release costs associated with PFOA or PFOS above the RQ of 1 lb per 24 hours are estimated to be approximately $561. This low cost is not expected to affect the demand for labor at regulated facilities.
Note, there may be some employment impacts resulting from federal property transfers. As described in Section 3.4, it is difficult to estimate the potential cost or impact resulting from these requirements.

SOURCES CITED
California Air Resources Board, "Chemical Fume Suppressants Approved for Use at Specific Surface Tensions," September 6, 2016. Available: https://www.arb.ca.gov/toxics/chrome/fumesuppresslistfinal9.6.16.pdf
California Water Boards, "Water Boards PFAS Phased Investigation Approach," March 6, 2019. Available: https://www.waterboards.ca.gov/pfas/docs/7_investigation_plan.pdf
Campbell, Katherine, Stephan E. Sefcik, and Naomi S. Soderstrom (1998), "Site uncertainty, allocation uncertainty, and superfund liability valuation," Journal of Accounting and Public Policy, Vol. 17 (1998): 331-366.
Environmental Protection Agency, "Envirofacts: TRI Search", July 2021. Accessed at: https://www.epa.gov/enviro/tri-search
Environmental Protection Agency, "Risk Management for Per- and Polyfluoroalkyl Substances (PFAS) under TSCA", 2021. Link: https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/risk-management-and-polyfluoroalkyl-substances-pfas
DHL. 2021. DHL eCommerce Solutions: Limited Quantity Policy. DHL. Accessed online Sept. 2021: https://www.dhl.com/content/dam/dhl/local/us/dhl-ecommerce/documents/pdf/us-ecommerce-limitied-quantity-transportation-policy.pdf
Environmental Protection Agency. "542-R-19-002: 2019 Remediation Market Study". January 15, 2020.
Environmental Protection Agency, "Basic Information for Chemical Data Reporting," August 29, 2016. Available: https://www.epa.gov/chemical-data-reporting/basic-information-chemical-data-reporting
Environmental Protection Agency, Designation of Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) as CERCLA Hazardous Substances. U.S. Environmental Protection Agency. 2022. Docket ID No. EPA-HQ-OLEM-2019-0341. https://www.regulations.gov
Environmental Protection Agency, "Enforcement and Compliance History Online (ECHO)", August 2021.
Environmental Protection Agency, "Envirofacts: TRI Search", July 2021. Accessed at: https://www.epa.gov/enviro/tri-search
Environmental Protection Agency. Certain perfluoroalkyl sulfonates.  U.S. Environmental Protection Agency. Code of Federal Regulations.  40 CFR 721.9582. 2014. https://www.govinfo.gov/content/pkg/CFR-2014-title40-vol31/pdf/CFR-2014-title40-vol31-sec721-9582.pdf
Environmental Protection Agency. Fact Sheet: 2010/2015 PFOA Stewardship Program.:Link: https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/fact-sheet-20102015-pfoa-stewardship-program
Environmental Protection Agency. Information Collection Request (ICR) No. 1049.14: Renewal of Information Collection Request for the Episodic Releases of Oil and Hazardous Substances. OMB Control No. 2050-0046, June 2018.
Environmental Protection Agency. Information Collection Request (ICR) No. 1395.10: Statement Supporting the Renewal of the Information Collection Procedure for Emergency Planning and Release Notification Requirements. OMB Control No. 2050-0092. April 2019.
  Environmental Protection Agency. Regulatory Impact Analysis: Final Rulemaking for 2017-2025 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, EPA-420-R-12-016, August 2012.
Environmental Protection Agency: Office of Environmental Justice. "Guidance on Considering Environmental Justice During the Development of Regulatory Actions". May 2015. Link: https://www.epa.gov/environmentaljustice/guidance-considering-environmental-justice-during-development-action
Environmental Protection Agency: Office of Environmental Justice. "Plan EJ 2014". September 2011. Link: https://www.epa.gov/environmentaljustice/plan-ej-2014
Environmental Protection Agency, "Per- and Polyfluoroalkyl Substances (PFAS): Incineration to Manage PFAS Waste Streams", July 2019. Available at:  https://www.epa.gov/sites/default/files/2019-09/documents/technical_brief_pfas_incineration_ioaa_approved_final_july_2019.pdf
Environmental Protection Agency, "Risk Management for Per- and Polyfluoroalkyl Substances (PFAS) under TSCA", 2021. Link: https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/risk-management-and-polyfluoroalkyl-substances-pfas
Environmental Protection Agency. "Superfund Enterprise Management System (SEMS). February 2022.
Environmental Protection Agency (U.S. EPA). Technical Fact Sheet -- Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA). 2017. Accessed online Sept. 2021: https://www.epa.gov/sites/default/files/2017-12/documents/ffrrofactsheet_contaminants_pfos_pfoa_11-20-17_508_0.pdf
Department of Defense: Office of the Under Secretary of Defense for Acquisition and Sustainment. "Per-and Polyfluoroalkyl Substances Cleanup Costs". July 2021.
Federal Aviation Administration. "National Plan of Integrated Airport Systems (NPIAS) - Current  -  Airports", October 07, 2020. Downloaded February 2022. Accessed at: https://www.faa.gov/airports/planning_capacity/npias/current/
Federal Register. Environmental Protection Agency, 40 CFR Part 721 - Perfluoroalkyl Sulfonates; Significant New Use Rule, December 9, 2002. Accessed online December 2021: https://www.govinfo.gov/content/pkg/FR-2002-12-09/pdf/02-31011.pdf
Federal Register. Environmental Protection Agency, 40 CFR Part 721 - Perfluoroalkyl Sulfonates; Significant New Use Rule, March 11, 2002. Accessed online December 2021: https://www.govinfo.gov/content/pkg/FR-2002-12-09/pdf/02-31011.pdf
FedEx. 2021. Service Guide. Fedex. Accessed online September 2021: https://www.fedex.com/content/dam/fedex/us-united-states/services/Service_Guide_2021.pdf
Genualdi, Susan; Jowri deJager; and Timothy Begley. Center for Food Safety and Applied Nutrition, Food and Drug Administration. 2019. "Investigation of Per- and Polyfluoroalkyl Substances (PFAS) in U.S. food products", Presentation at the 29th annual European meeting of the Society of Environmental Toxicology and Chemistry
Glüge, J; Scheringer, M; Cousins, IT; DeWitt, JC; Goldenman, G; Herzke, D; Lohmann, R; Ng, CA; Trier, X; Wang, Z. (2020). An overview of the uses of per-and polyfluoroalkyl substances (PFAS). Environ Sci Process Impacts 22: 2345-2373. https://www.ncbi.nlm.nih.gov/pubmed/33125022
Graff Zivin, Joshua and Matthew Neidell. (2018). "Air pollution's hidden impacts: Exposure can affect labor productivity and human capital," Science. Vol. 359, Issue 6371.
Graff Zivin, Joshua and Matthew Neidell. (2013). "Environment, Health, and Human Capital," NBER Working Paper 18935, April 2013; and
Graff Zivin, Joshua and Matthew Neidell. (2012). "The impact of Pollution on Worker Productivity," American Economic Review. Vol. 102(7): 3652-3673.
Hogue, Cheryl. "Governments Endorse Global PFOA Ban, With Some Exemptions," Chemical & Engineering News, May 6, 2019. Available: https://cen.acs.org/environment/persistent-pollutants/Governments-endorse-global-PFOA-ban/97/web/2019/05
Hogue, Cheryl. "Impacts of Used PFAS into U.S. Scrutinized," Chemical & Engineering News, March 3, 2019. Available: https://cen.acs.org/environment/persistent-pollutants/Imports-used-PFAS-US-scrutinized/97/i9
Hu, Xindi C.,,David Q. Andrews, Andrew B. Lindstrom, Thomas A. Bruton, Laurel A. Schaider, Philippe Grandjean, Rainer Lohmann, Courtney C. Carignan, Arlene Blum, Simona A. Balan, Christopher P. Higgins, and Elsie M. Sunderland. Environmental Science & Technology Letters. 2016. "Detection of Poly- and Perfluoroalkyl Substances (PFASs) in U.S. Drinking Water Linked to Industrial Sites, Military Fire Training Areas, and Wastewater Treatment Plants".
ICF. 1985. Regulatory Impact Analysis of Reportable Quantity Adjustments Under Sections 102 and 103 of the Comprehensive Environmental Response, Compensation, and Liability Act. Volume 1:  A Report to the Oil and Hazardous Materials Spills Branch Office of Research and Development and Environmental Response Division, Office of Emergency and Remedial Response, U.S. EPA. EPA Contract 68-03-03182
Interstate Technology and Regulatory Council, "12 Treatment Technologies". August 2021. Available at: https://pfas-1.itrcweb.org/12-treatment-technologies/#12_3 .
Interstate Technology and Regulatory Council, "PFAS Fact Sheets," 2018. Available: https://pfas-1.itrcweb.org/fact-sheets/
Interstate Technology and Regulatory Council, "Regulations, Guidance, and Advisories for Per- and Polyfluoroalkyl Substances (PFAS)," January 2018. Available: https://pfas-1.itrcweb.org/wp-content/uploads/2018/01/pfas_fact_sheet_regulations__1_4_18.pdf
Interstate Technology and Regulatory Council, "History and Use of Per- and Polyfluoroalkyl Substances (PFAS)". April 2020. Available at: https://pfas-1.itrcweb.org/fact_sheets_page/PFAS_Fact_Sheet_History_and_Use_April2020.pdf
Khanna, Madhu, Wilma Rose H. Quimio, and Dora Bojilova. (1998). "Toxics Release Information: A Policy Tool for Environmental Protection," Journal of Environmental Economics and Management, Vol. 36(3): 243-266.
Konar, Shameek and Mark A. Cohen. (1997), "Information As Regulation: the Effect of Community right to Know Laws on Toxic Emissions," Journal of Environmental Economics and Management, Vol. 32, pp. 109-124.