On December 20, 2023, the Washington state department of ecology (ecology) released for public comment the State Environmental Policy Act (SEPA) draft environmental impact statement (DEIS) on its proposed aqueous film foaming [forming] foam (AFFF) collection, transport, and disposal program. The comment period runs through February 5, 2024.

AFFF contains per and polyfluoroalkyl substances (PFAS). PFAS are a group of thousands of chemicals used to make fluoropolymer coatings and products that resist heat, oil, stains, grease, and water. PFAS have one of the strongest chemical bonds known to humanity. This bond leads to the chemicals' persistence in the environment and makes their safe and complete destruction difficult. Further, PFAS are toxic at minute levels and known to cause negative health impacts on reproductive systems, auto-immune responses, and cancer. AFFF is the suspected primary source of PFAS drinking water contamination across the state.

In November 2021, ecology launched a SEPA review of an AFFF disposal program. The review includes an analysis of the environmental and public health impacts, possible mitigation measures, and five proposed disposal options:

The AFFF DEIS describes the probable environmental and public health impacts associated with the five disposal options. The DEIS also details proposed mitigation measures to eliminate or reduce these impacts.

Ecology welcomes public comments on all aspects of the DEIS including the proposed disposal options, the potential impacts, and possible mitigation. Comments that include the following are most helpful:

Ecology will review submitted comments and incorporate substantive new information into the final EIS. We anticipate releasing the final EIS, with a selected disposal option, by spring 2024.


•	Approved hold in place.
•	Incineration.
•	Solidification and landfilling.
•	Class 1 deep-well injection.
•	No action.


•	A reference to the EIS section where your specific comments pertain.
•	Specific aspects of the EIS one does or does not support.
•	Recommendations on how the DEIS could be improved or strengthened.
•	Suggestions on additional analysis that should be conducted or input on the analysis that was completed.
•	Clarification or correction of material provided in the DEIS.
•	Submission of additional information including research, reports, and/or studies that will assist ecology in the decision-making process.

The public comment period opens December 20, 2023, and runs for 45 days, until February 5, 2024. Interested parties can submit comments via ecology's eComments http://ecology.wa.gov/AFFF-comment; by email AFFFDisposal@ecy.wa.gov; or by mail at Washington State Department of Ecology, Attention Sean Smith/AFFF DEIS Comments, P.O. Box 330316, Shoreline, WA 98133-9716.

During the comment period, ecology will hold an informational meeting on January 17, 2024, where the public can learn more about the EIS and have their questions about it answered. We will also hold a public hearing on January 31, 2024, during which the public can submit written and verbal comments for the record. Find more information on these meetings and how to register on our web page at http://ecology.wa.gov/AFFF-comment.

Please visit ecology's web page at http://ecology.wa.gov/AFFF-comment to download a copy of the draft EIS. To get more information on the DEIS, please contact Sean Smith at 425-324-0328, Sean.Smith@ecy.wa.gov, or P.O. Box 330316, Shoreline, WA 98133-9716.