EPA rescinds water guidance and policy on extreme weather, PFAS, emerging contaminants, UIC, and functional equivalence

September 18, 2026

As part of the U.S. Environmental Protection Agency’s commitment to accessibility, transparency, and fair notice, the Office of Water identified guidance documents needing rescission to comply and align with current laws, regulations, and policies, and in some cases determined to require public input.

The Office of Water’s decision was also informed in part by stakeholder recommendations submitted in response to the Office of Management and Budget’s “Request for Information” regarding deregulation.

The table below identifies the guidance and policy subject to this action, the intent of the guidance and policy, and the reason cited for rescission in the decision memorandum of the EPA Office of Water Assistant Administrator Jessica Kramer, effective August 11, 2026, to EPA Water Program Directors.

EPA WATER PROGRAM GUIDANCE  & POLICY BEING RESCINDED AS OF AUGUST 11, 2026
Guidance/Policy Rescinded Purpose of Guidance/Policy Reason for Rescission
   
Guidance “Climate Change Considerations When Prioritizing, Developing, and Implementing Total Maximum Daily Loads” (November 2024) Identifies a non-exhaustive selection of potential approaches for incorporating global climate change concerns into the development of total maximum daily loads Does not align with recent Executive Orders and Administration priorities on global climate change concerns
Policy Memorandum “Environmental Justice Guidance for UIC Class VI Permitting and Primacy” (August 17, 2023) Encourages states to consider environmental justice and climate resiliency in a range of UIC Class VI permitting considerations, including siting decisions, evaluating applications for primacy, and implementation Does not align with recent Executive Orders and Administration priorities regarding environmental justice and energy dominance
Policy Memorandum “Addressing PFAS Discharges in NPDES Permits and Through the Pretreatment Program and Monitoring Programs” (December 5, 2022) Encourages states and wastewater utilities to use existing Clean Water Act authorities to direct industries to pretreat wastewaters to prevent  PFAS pollution from entering drinking water sources, rivers, and communities. Memorandum has caused confusion for states and permittees and resulted in inconsistent application - Inappropriate conflation of maximum contaminant levels under the Safe Drinking Water Act with separate Clean Water Act permitting requirements related to water quality standards. Guidance should be vetted through public review and comment.
Fact Sheet “Implementing Case-by-Case Technology-Based Effluent Limitations in NPDES Permits for Pollutants of Emerging Concern” (January 2025) Expands the scope of industrial wastewater treatment permits under 40 CFR 125.3(c)(2) to also include pollutants of emerging concern where no federal guideline exists Inconsistent application across the country - should be vetted through public review and comment.
Draft Guidance “Applying the Supreme Court’s County of Maui v. Hawaii Wildlife Fund Decision in the Clean Water Act Section 402 National Pollutant Discharge Elimination System Permit Program to Discharges through Groundwater” (November 2023) Provides guidance to permit writers for determining when a discharge from a point source to “waters of the United States” that travels through groundwater is the “functional equivalent of a direct discharge” to WOTUS and therefore requires a federal Clean Water Act permit EPA published the draft guidance for public comment, but it was never finalized. Rescission prevents confusion and ensures that states do not rely on draft guidance not finalized. Office policy: draft documents must be finalized within two years of the draft date or will automatically be rescinded.

 
Click here to read the EPA Decision Memorandum.