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options, such as state and federal grants and loans, one forward-thinking strategy is to hold polluting PFAS manufacturers accountable through legal action. Now that drinking water utilities have reached multibillion-dollar settlements with PFAS manufacturers 3M and DuPont, many municipal utilities are considering their next steps to recover costs beyond drinking water. As a proactive approach, wastewater systems across the country are using litigation as a funding source—whether or not they have yet incurred PFAS- related expenses. By understanding the legal and financial risks that PFAS may present, and by exploring available funding opportunities, municipal authority leaders can build resilience. PFAS Wastewater Monitoring in Pennsylvania Since 2024, Pennsylvania’s public wastewater utilities have been adapting to new PFAS monitoring guidelines that have been incorporated into National Pollutant Discharge Elimination System (NPDES) applications and renewals. The initiative promotes sampling for four PFAS compounds: PFOA, PFOS, HFPO-DA, and PFBS. If any of these contaminants are detected above reporting limits, then the wastewater system may be subject to quarterly monitoring requirements. If none of the above PFAS compounds are detected above reporting limits, then annual monitoring may suffice. Wastewater utilities are only released from PFAS monitoring obligations after four consecutive monitoring periods showing values below the reporting limits for all four PFAS compounds. Although Pennsylvania has not yet enacted regulations restricting the discharge of wastewater or the disposal of biosolids containing PFAS, that could change in the years ahead if the state follows other states’ examples. In many states across the country, particularly in New England, PFAS monitoring programs have led to further regulatory development—and significant cost increases for utilities forced to manage contaminants they had no role in producing. PFAS Wastewater & Biosolids Regulations Gain Nationwide Momentum In recent years, there has been a growing nationwide trend towards stricter state regulation of wastewater and biosolids in an effort to control the spread of PFAS contamination. By learning from their examples, wastewater professionals in Pennsylvania can better prepare for the potential development of regulations in their own state. In 2022, Maine became the first state in the country to ban the land application and sale of biosolids and compost containing sewage sludge. Then, in 2024, Connecticut also banned the use or sale as a soil amendment of any biosolids or wastewater sludge containing PFAS. Other states, including Colorado, Massachusetts, Maryland, Michigan, Minnesota, New Hampshire, New York, and Wisconsin, have all begun to regulate PFAS in biosolids through testing, reporting requirements, tiered PFAS limits, or limitations on land application. The regulatory momentum shows no signs of slowing down: In Virginia, a new law effective January 2027 mandates monthly PFAS sampling of sludge for land application, transitioning to quarterly testing after one year. Additionally, in spring 2026, New York lawmakers considered a bill that would impose a five-year moratorium on the land application of biosolids. Although New York’s 2026 legislative session concluded without passing the bill, there may be attempts to pass similar legislation during future sessions. Funding Options for Wastewater Systems Municipal authorities do not produce or benefit from PFAS, but in many states, the current regulatory landscape is putting increasing pressure on them to address these “forever chemicals.” In affected areas nationwide, this has led to exponential cost increases and major disruptions to systems that have worked for decades. While some state and federal funding has been made available for utilities affected by PFAS, utilities may find that many sources cover only part of their PFAS-related expenses. By I N RECENT YEARS , THERE HAS BEEN A GROWING NATIONWIDE TREND TOWARDS STRICTER STATE REGULATION OF WASTEWATER AND BIOSOLIDS IN AN EFFORT TO CONTROL THE SPREAD OF PFAS CONTAMINATION .

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