PFAS are ubiquitous. As states adopt increasingly stringent PFAS groundwater standards, the potential effect on land development deserves attention.
Wisconsin has now established enforceable groundwater standards for six PFAS compounds, including 4 ppt for PFOA and PFOS. [content.go...livery.com]
For Florida, the concern is practical. If future PFAS GCTLs approach potable-water limits, even relatively low concentrations could trigger additional assessment, monitoring or remediation. Where PFAS originated off-site and migrated through groundwater, determining responsibility may be equally challenging.
Add this to Florida's continuing CWA §404 permitting uncertainty following Sackett, and the development picture becomes increasingly complicated.
Environmental due diligence may soon require developers to evaluate not only wetlands and jurisdictional boundaries, but also PFAS in groundwater at concentrations measured in ppt.
The environmental objective is clear. The economic consequences may be much less so.