EPA's Proposed PFAS Rule Changes: What Small Water Systems Should Do Now

On May 18, 2026, EPA proposed two separate rules that would reshape the 2024 PFAS drinking water regulation. The first would rescind the regulatory determinations and Maximum Contaminant Levels for four of the six regulated PFAS: PFHxS, PFNA, HFPO-DA (better known as GenX), and the Hazard Index mixture standard that covered combinations of those compounds. The second would extend the compliance deadline for the PFOA and PFOS standards by two years, from 2029 to 2031.

Both are proposals, not final rules. Comment periods for both close July 20, 2026, and EPA held a public hearing on July 7, 2026. Harvard Law's Environmental & Energy Law Program maintains a regulatory tracker that follows both dockets and is the cleanest single reference for where things stand.

The underlying regulation, the PFAS National Primary Drinking Water Regulation finalized April 26, 2024, set enforceable MCLs for six PFAS and required drinking water systems to complete initial PFAS monitoring by 2027, with compliance originally due in 2029. There is also litigation in the background: water-sector trade associations challenged the 2024 rule in American Water Works Association v. EPA in the D.C. Circuit. Between the proposals and the lawsuit, the final shape of PFAS regulation is genuinely uncertain. What is not uncertain is what remains on the books today.

The part of the 2024 rule that hits small systems first is the part EPA left alone. The requirement to complete initial PFAS monitoring by 2027 remains in place under both proposals. So do the PFOA and PFOS standards themselves. What EPA proposed to move is the date by which systems must comply with those two standards, and what it proposed to remove is the four other standards. The obligation to sample, generate defensible data, and know your numbers has not gone anywhere.

That distinction matters for planning. A system that reads the headlines as "PFAS rules rolled back" and shelves its sampling plan is setting itself up for a compliance problem on the schedule that never moved. A proposed deadline extension is relief only if it becomes final, and a rescission proposal can be revised, withdrawn, or litigated. The conservative read for an operator is simple: treat 2027 monitoring as fixed, treat the PFOA and PFOS standards as fixed, and treat everything else as in motion.

Deadline relief is proposed, not final. The 2027 monitoring requirement and the PFOA and PFOS standards remain in place today.

While the rulemaking plays out, money is moving. In late June 2026, EPA announced more than $25 million through the SmaRT (Small, Rural, and Tribal) Drinking Water Assistance Program, the renamed Small, Underserved, and Disadvantaged Communities program established under the WIIN Act. The funding is administered by states and targets public water system upgrades for PFAS treatment, lead reduction, and Safe Drinking Water Act compliance. WaterWorld covered the announcement on June 29, and flagged it on X the same week.

The state allocations that matter for our region: Ohio receives approximately $639,000 and Pennsylvania approximately $732,000. Those are not transformative sums at the state level, but SmaRT is aimed specifically at the small systems that have the hardest time funding compliance work out of rate revenue. For a small system with a known monitoring or treatment gap, this is exactly the kind of program worth a call to your state drinking water program.

The temptation when rules are in flux is to wait. For PFAS, waiting is the wrong bet, because the near-term obligations are the ones that did not move. A practical sequence:

1. Confirm your initial monitoring plan against the 2027 requirement. If sampling is not scheduled, on contract with a certified lab, and documented, that is the first gap to close.
2. Get your data house in order. PFAS compliance is a records exercise as much as a treatment exercise. Sampling locations, chain of custody, and results need to be organized so they hold up when the state reviews them. Reliable instrumentation and data logging on the plant side make the rest of the record easier to defend.
3. Track the July 20 comment deadline and the final rules. Whatever EPA finalizes will set your actual compliance date for PFOA and PFOS. Until then, plan against 2029 and treat 2031 as a possibility, not a promise.
4. Look at SmaRT and your state programs for funding. The program is administered by states, so eligibility and application mechanics run through your state drinking water program, not EPA directly.
5. Fix known gaps while the window is open. If your system already knows it has weak spots in monitoring, chemical feed control, or data collection, funding aimed at small systems is the right moment to address them rather than betting the rollbacks land.

Control Associates works on the monitoring and controls side of this problem: compliance monitoring, instrumentation, data logging, and chemical feed systems. We do not design PFAS treatment plants. What we do is make sure the sampling, instrumentation, and records that sit underneath a compliance program are accurate and defensible, which is where most small systems in Ohio and Western Pennsylvania actually fall short first. We have been doing that kind of work for water systems since 1968, across more than 5,500 installed systems.

Not sure where your gaps are?

Talk to Steve, our Director of Sales Engineering. He helps small systems scope monitoring and instrumentation upgrades and frame them for state funding programs.

Call+1(440) 708-1770

Emailsteveb@controlassociatesinc.com