American Farmland Trust has filed formal comment on the U.S. Environmental Protection Agency's draft guidance addressing PFAS in biosolids, inserting one of the country's largest farmland advocacy organizations into a rulemaking arena that sits squarely at the junction of wastewater infrastructure, agricultural soils and fluorinated chemistry.

The comment, submitted through the federal docket and reported by Morning Ag Clips, concerns guidance that will shape how the agency handles per- and polyfluoroalkyl substances — the persistent fluorinated compounds used across industrial and consumer applications — in treated sewage sludge that utilities spread on farmland as fertilizer and soil amendment.

Biosolids sit in an awkward regulatory position. The Clean Water Act's Part 503 standards, written in 1993, govern pathogens and heavy metals in land-applied sludge. They do not set numeric limits for PFAS, even though the compounds pass through wastewater treatment plants largely intact and partition into the sludge cake. EPA has spent several years building the analytical and risk-assessment record that could change that, including its PFAS Strategic Roadmap and a scheduled round of effluent limitation and biosolids risk-assessment work.

Why a farmland group is commenting

American Farmland Trust's interest follows directly from the material stream. Roughly half of the biosolids produced by U.S. wastewater utilities each year is land-applied, which makes working farms the receiving environment for whatever the treatment train fails to remove. For an organization whose mandate centers on keeping agricultural land productive and protected, PFAS in biosolids is a soil-legacy question: once fluorinated compounds enter a field, they persist, and the farmer — not the utility or the chemical manufacturer — typically owns the contamination problem.

That asymmetry drives the stakeholder dynamics. Municipal utilities defend land application as the lowest-cost, highest-value outlet for sludge that would otherwise go to landfill or incineration. Food processors and dairy operators increasingly test for PFAS in milk and crops. State regulators in Maine and Michigan have already built their own biosolids screening programs, in part because federal guidance lagged. Maine went further and banned land application of biosolids outright in 2022.

What does this change for biosolids handling?

In the near term, an AFT comment does not change any permit or any tonnage. Comments on draft guidance signal to EPA which constituencies will contest or support the final text, and where litigation risk sits. What the group's engagement does establish is that agricultural landowners — not just wastewater agencies and environmental groups — intend to participate in shaping the federal framework.

The practical question for utilities and haulers is whether EPA's final guidance will push toward numeric screening values, testing obligations at the treatment plant, or disclosure requirements along the land-application chain. Each of those paths carries cost. Laboratory analysis for the dozen-plus PFAS compounds EPA now routinely measures runs well above conventional sludge testing, and sludge that fails a screening threshold loses its fertilizer market and moves to disposal outlets with higher tipping fees.

The deadline that decides what happens next

The immediate milestone is the close of the docket and EPA's eventual issuance of final guidance. Under the agency's published PFAS roadmap schedule, biosolids risk-assessment work feeds into later regulatory determinations, and the next round of effluent guidelines for PFAS manufacturers and metal finishers — sources whose discharges end up in sewage sludge — runs on its own clock.

Watch two signals. First, whether EPA's final text adopts screening benchmarks that states can adopt by reference, which would standardize a patchwork that currently varies from Michigan's numeric limits to states with no program at all. Second, whether the agency commits to a date for a formal Part 503 revision, which would convert guidance into enforceable limits.

The docket record, including AFT's comment, now forms part of the administrative file EPA must answer before it finalizes. That filing — not the press release — is what the sector will parse for direction.