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Worksheet Grade 11 Social Studies & Civics

Two PFAS Standards: A Grade 11 Morvane Bill Analysis Worksheet

Students analyze a fictional state PFAS bill against the federal drinking water rule, weighing testimony from a small utility and a health advocate.

Objectives

  1. Students will explain why a federal drinking water standard sets a floor that states may make stricter.
  2. Students will identify the incentives a state bill creates for dischargers, utilities, and ratepayers.
  3. Students will evaluate a proposed state standard against its stated purpose and name one unintended outcome.

Vocabulary

Maximum contaminant level (MCL)
A maximum contaminant level, or MCL, is the highest amount of a certain substance that federal rules allow in drinking water. Water systems test regularly to prove their water stays under each limit.

Also: preemption, fiscal note, cost recovery, primacy

Teacher overview

The legislature of Morvane, a fictional state, is considering Senate Bill 214, which would set a state drinking water limit for two PFAS compounds below the federal number and would create a state fund to help small systems pay for treatment. Students read five short documents written for this worksheet and decide what the bill would actually change, whom it would cost, and what it would leave unresolved. The misconception worth naming before students begin is the common belief that a federal standard is a ceiling states may not exceed. Under the Safe Drinking Water Act the national standard is a floor, and a state with primacy may adopt a stricter limit while it may never adopt a weaker one.

Two PFAS Standards: A Grade 11 Morvane Bill Analysis Worksheet — Grade 11 Social Studies & Civics
Name: ____________________________ Date: ______________

Student Worksheet

Document A. The federal rule. In April 2024 the Environmental Protection Agency set a national maximum contaminant level of 4.0 parts per trillion each for two PFAS compounds, PFOA and PFOS, with compliance required by April 2029. In May 2026 the agency proposed letting eligible systems apply for a two-year exemption, to April 2031. The exemption would not be automatic for every system, the 4.0 limit would not change, and the proposal was not yet final as of September 2026. States that run their own drinking water programs may set stricter limits than the national rule. They may not set weaker ones.

Document B. Morvane Senate Bill 214 (a fictional bill). Section 1 sets a state limit of 2 parts per trillion each for PFOA and PFOS, with compliance required by 2030. Section 2 creates the Morvane Small System Treatment Fund, appropriating $40 million for one two-year period, with no guarantee of renewal. Section 3 allows a water system to sue a manufacturer that discharged PFAS into its source water to recover treatment costs.

Document C. Testimony of the Wrayling water superintendent (fictional). Wrayling serves 6,400 people from two wells beside the Durnford River. Meeting the state limit would require a granular activated carbon plant, and the fund would cover only part of the construction. Wrayling has no staff engineer, and the town would carry the operating cost, including carbon changeouts, for as long as the plant runs.

Document D. Testimony of a public health advocate (fictional). The advocate argues that PFAS compounds stay in the body for years and that the proposed federal exemption would leave people served by exempted systems drinking water with known contamination for up to two more years. She asks the committee to treat the state limit as a health decision first and a cost decision second.

Document E. Fiscal note (fictional). Legislative staff estimate that 61 of Morvane's 340 community water systems would need new treatment. The note projects that the fund would cover roughly a third of the total capital cost in the first two years and states that remaining costs would fall on local ratepayers.

  1. According to Document A, what is the federal limit for PFOA and PFOS, and what change did the agency propose in 2026?
  2. Document B sets a different number. Which limit would a Morvane water system have to meet, and why is that the case?
  3. Explain in two sentences why Morvane may adopt a stricter limit but not a weaker one.
  4. Section 3 lets a utility sue a manufacturer for treatment costs. Name the incentive this creates for a company that handles PFAS in Morvane.
  5. Using Document C, name two costs the bill would place on a system the size of Wrayling.
  6. Using Document D, state the advocate's central claim and the reasoning she offers for it.
  7. According to Document E, who pays for the treatment the bill requires after the first two years?
  8. Name one unintended outcome the bill could produce for a small system, and explain the chain of events that would lead to it.
  9. The superintendent and the advocate disagree about the bill. Identify one thing they appear to agree on.
  10. Propose one amendment that addresses the Wrayling problem without weakening the health limit, and state the tradeoff your amendment accepts.
  11. In three to four sentences, evaluate Senate Bill 214 against its stated purpose of reducing PFAS exposure in Morvane. Use at least two documents.

From Water for Schools (waterforschools.org). This material is in the public domain (CC0) and may be copied, edited, and shared freely.

Answer Key
  1. Answer: 4.0 parts per trillion each for PFOA and PFOS, with a proposed two-year exemption.
    Document A gives the April 2024 maximum contaminant level of 4.0 parts per trillion each, with compliance required by April 2029, and states that in May 2026 the agency proposed letting eligible systems apply for an exemption to April 2031 without changing the limit.
  2. Answer: The state limit of 2 parts per trillion. A state drinking water program may set a stricter limit than the national rule, and a system must meet whichever standard is stricter.
  3. Answer: The national standard is a floor rather than a ceiling. The Safe Drinking Water Act lets a state with primacy require more protection than the federal rule, while a weaker state limit would leave residents below the national minimum and would not be approved.
  4. Answer: It shifts part of the expected cleanup cost onto the discharger. A company that expects to pay for downstream treatment has a financial reason to reduce or capture its PFAS discharges before a lawsuit becomes likely. Accept answers naming reduced discharge, improved handling, or earlier settlement.
  5. Answer: Construction cost not covered by the fund, and long-term operating cost. Document C names the carbon plant itself, the carbon changeouts, and the absence of a staff engineer. Credit any two of these.
  6. Answer: That the state should set the limit on health grounds first. Her reasoning is that PFAS compounds persist in the body and that the proposed federal exemption would extend exposure by up to two years for people served by systems that receive it.
  7. Answer: Local ratepayers. The fiscal note projects the fund covering roughly a third of capital cost in the first two years, with the remainder and all later costs falling on local bills.
  8. Answer: Rate increases or consolidation pressure on small systems. A plausible chain is that Wrayling must build and operate treatment, the fund expires, bills rise sharply for a small customer base, and the town either raises rates steeply or seeks a merger with a larger system. Accept any chain that names a mechanism rather than only an outcome.
  9. Answer: That the contamination is real and requires treatment. Neither witness disputes that PFAS is present or that treatment works; they disagree about who should pay and how quickly.
  10. Answer: Any amendment that holds the limit and shifts cost or timing. Examples include making the fund permanent, giving systems under a stated size a longer compliance schedule, or funding a shared circuit-rider engineer. Each answer must state a tradeoff, such as higher state spending or continued exposure during a longer schedule.
  11. Answer: A reasoned evaluation using at least two documents. Strong responses note that the bill would lower the allowed concentration and create a cost recovery tool, yet the fiscal note and the Wrayling testimony together show that funding ends before the obligation does, so the stated purpose is only partly served.

Differentiation

Support

Give students a two-column note catcher labeled "What the bill requires" and "Who pays" and have them fill it in from Documents B, C, and E before answering any item. Pre-mark Document A with the sentence that establishes the floor-not-ceiling rule so item 3 has a visible anchor.

Extension

Have students write the two-paragraph committee report that would accompany a favorable vote, stating the bill's purpose, the principal objection raised in testimony, and the committee's answer to that objection.

ELL supports

Pre-teach "maximum contaminant level," "preemption," "fiscal note," and "cost recovery" with a short definition and one example sentence each. Provide sentence frames for items 8 and 11: "One result the sponsors did not intend is ___, because ___." and "The bill would achieve part of its purpose because ___, but it would fall short because ___."

Extensions

Students compare the structure of Senate Bill 214, a fictional bill, with the structure of a real state drinking water statute available from a state legislature's public website, listing which sections appear in both and which appear in only one.