Four critical steps airports can take to navigate PFAS regulations

Airports are under mounting pressure to address issues associated with aqueous film-forming foam (AFFF) transition and legacy contamination from per- and polyfluoroalkyl substances, making proactive compliance, planning and risk management essential to navigate current regulatory uncertainty.

United States | Thursday, June 5, 2025
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As public pressure increases and regulatory uncertainty grows regarding per- and polyfluoroalkyl substances (PFAS), airports are facing significant operational and compliance challenges. From firefighting foam transition to environmental remediation and stormwater discharge permitting, airports should act now to stay ahead where regulatory drivers are imminent.

Here are four essential steps to manage PFAS risk and meet evolving requirements.

1. Plan for the Firefighting Foam Transition

In 2025, the transition away from aqueous film-forming foam (AFFF) is affecting airports — whether due to lack of clarity on truck cleaning procedures and “how clean is clean enough” for their firefighting equipment or output-based testing requirements by the Federal Aviation Administration (FAA) after transition to fluorine free foams (FFF). Some states requiring transition within a certain time frame or imposing waste management restrictions. This shift brings operational, training and disposal challenges:

Proper storage, removal and disposal of legacy AFFF.
Clean, retrofit and/or replace Aircraft Rescue and Fire Fighting (ARFF) vehicles to accept the new FFF.
Train appropriate staff on how to use the new FFF. FFF do not form a protective layer characteristic of AFFF foams so require different application techniques to be effective.
Account for ARFF downtime, equipment cleaning and waste management of the resultant rinseate and other materials in your transition plan.
Procedures for performing output-based testing in an environmentally protective manner and managing the resulting materials.
Tip: Where possible, engage with state take-back programs early and test new foams post-installation to verify performance. Develop your transition and waste management plans well ahead of actual transition.

2. Address Clean Water Act and National Pollutant Discharge Elimination System (NPDES) Monitoring Requirements

Under the Clean Water Act, the EPA now includes airports in PFAS monitoring guidance for NPDES permits. A growing number of states are requiring routine PFAS monitoring of discharges. If PFAS are detected in outfalls, corrective measures, including source reduction plans, may be required.

Recommended actions:

Perform desktop evaluations under the guidance of your attorney to understand your airport's vulnerability to surface water discharge impacts as well as discharges that may come onto your airport from off property sources.
Conduct strategic sampling — ideally under legal counsel — to understand discharge profiles.
Stay informed about your state’s position on PFAS in water discharges, pretreatment and source reduction (especially if operating in states that are aggressively regulating PFAS).

3. Incorporate PFAS Management into Construction and Dewatering Projects

PFAS can be present in soils, construction materials and groundwater — especially near fire training areas, fuel storage and historic spill sites. During airport upgrades, contaminated media may be encountered, triggering costly delays or disposal requirements. Improper PFAS waste management could present Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) liability. Two of the most commonly encountered PFAS, perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), are designated as hazardous substances under CERCLA. An airport could be considered a potentially responsible party if PFAS containing materials (e.g., impacted soil) were improperly disposed of. The airport would potentially be subject to strict, and joint and several liabilities for the cost of cleanup.

What to do:

Update soil and groundwater management plans to account for PFAS.
Identify known or suspected PFAS impact areas early in the design process.
Include PFAS sampling, materials management, transportation and disposal costs in capital planning.
Know where PFAS-impacted soils, construction debris and tailwater from construction dewatering operations can be legally disposed of, or how they will be managed on site in an environmentally acceptable manner.
If tailwater can be cost effectively treated on-site, understand the regularity requirements for your airport for discharge to a publicly owned treatment work, or through your existing stormwater permit.
Ensure your construction contractor understands how to implement your PFAS impacted media and is willing to do so.

4. Strengthen Your Environmental Investigation and Compliance Strategy

With current legal challenges to Federal regulation of PFAS through CERCLA and Safe Drinking Water Act maximum contaminant levels (MCLS) and the lack of definition on the EPA’s plan of having “polluters pay”, it is currently unclear if airports will be financially responsible to remediate environmental media impacted by PFAS. It is clear that many states, backed by public sentiment, have enacted their own clean-up requirements for PFAS and most states manage Clean Water Act wastewater/storm water discharge permitting, which increasingly include PFAS-onerous monitoring and source reduction requirements that are applicable to airports.

Next steps:

Develop a comprehensive airport wide PFAS management strategy that involves key airport stakeholders (environmental, operations, firefighters, legal, community involvement etc.).
Develop a robust Conceptual Site Model identifying known or suspected PFAS impacted soil and groundwater areas, sensitive receptors on airport property and off airport property (including stormwater outfalls), and areas where earth disturbing activities are anticipated. Engage legal counsel help define current and potential PFAS liabilities.
Develop a comprehensive airport wide PFAS management strategy that involves key airport stakeholders (environmental, operations, firefighters, legal, community involvement etc.).
Prepare for potential investigations and compliance sampling driven by state regulations, public demand or lawsuits.
Monitor evolving regulations regarding maximum contaminant levels and cleanup goals on the federal and state levels.
If investigation and remediation are required, use engineering firms that know how to employ the required specialized sampling methods, know which laboratories are certified to perform PFAS analysis and are experienced in PFAS remedial alternative evaluation and remedial design.

PFAS regulation is moving fast, and airports are firmly in the spotlight. By taking proactive steps in foam transition, construction planning, investigation and discharge monitoring, airport leaders can reduce risk, improve compliance and protect public trust.