PFAS at Municipal Fire Training Sites: What Local Leaders Need to Know

For decades, municipal fire departments relied on aqueous film-forming foam, commonly known as AFFF, to suppress dangerous fuel fires and conduct live-fire training. Firefighters used these products because they were effective, widely recommended, and, in some cases, required for certain applications.

Many local governments are now learning that the effects of historical AFFF use may extend far beyond the fireground.

AFFF contains per- and polyfluoroalkyl substances, or PFAS, a broad class of synthetic chemicals that can persist in soil and water for many years. Where AFFF was repeatedly used, stored, tested, or disposed of, PFAS may remain in the surrounding environment and could affect groundwater, surface water, or nearby drinking water sources.

For municipal leaders, the question is no longer limited to whether a fire department still has AFFF in storage. The larger issue is whether past use may create future operational, financial, and legal obligations for the local government that owns the property.

Why Municipal Fire Training Sites Are Receiving More Attention

Historical fire training areas were often designed around the accepted practices and knowledge of the time. Departments conducted drills on open ground, tested equipment, flushed foam systems, and cleaned trucks or gear after use.

Local governments and firefighters were not warned that PFAS compounds could remain in the environment long after the foam disappeared. However, even decades later, areas where AFFF was discharged can still be affected by PFAS contamination, which can also migrate through soil and water. This issue is especially relevant for municipalities that own:

• Fire training facilities

• Public safety campuses

• Municipal airports

• Public works yards

• Properties where AFFF was stored or tested

• Sites used for emergency-response training

In many cases, the fire department may hold the most useful historical information about if and where AFFF was used, and how often. However, the financial and legal consequences can extend beyond the department itself and become a broader municipal concern.

The Costs May Begin Before Cleanup

PFAS-related costs do not always begin with a large remediation project.

Many local governments have already incurred expenses associated with the transition from legacy AFFF, including:

• Purchasing fluorine-free foam

• Disposing of old AFFF inventories

• Replacing or cleaning equipment

• Updating training procedures

• Evaluating storage areas

• Reviewing records of historical use

• Consulting with environmental or legal professionals

Additional expenses may arise if a municipality determines that further investigation is warranted. These can include soil or groundwater assessments, long-term monitoring, engineering support, regulatory compliance, and communication with nearby residents or water systems.

Even when contamination has not been confirmed, uncertainty itself can create costs. Staff may need to locate old records, coordinate across departments, respond to public questions, or evaluate whether past practices could affect current municipal property.

Why PFAS Liability Remains a Municipal Issue

In 2024, the U.S. Environmental Protection Agency designated PFOA and PFOS, two PFAS compounds commonly associated with AFFF, as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act.

EPA has indicated that it generally does not intend to prioritize certain passive receivers, including some public agencies, for federal CERCLA enforcement. However, enforcement discretion is not the same as exemption from liability.

Municipalities may still face:

• State-level regulatory requirements

• Claims brought by private parties

• Costs associated with investigating contamination

• Expenses related to nearby drinking water impacts

• Operational restrictions on municipal property

• Future monitoring or remediation obligations

The practical concern for local leaders is that a municipality may face significant financial exposure even if it did not manufacture PFAS or knowingly create a contamination problem.

Fire departments used products that were accepted at the time. The local government may nevertheless be left managing the consequences decades later.

Questions Municipal Leaders Should Begin Asking

PFAS at fire training sites is rarely an issue that belongs to only one department. Addressing it may require coordination among fire leadership, public works, finance, legal counsel, environmental staff, elected officials, and outside consultants.

Useful early questions may include:

• Did the municipality operate a dedicated fire training site?

• Was AFFF historically stored, tested, or used – and, if so, where?

• Were training exercises conducted near wells, surface water, drains, or neighboring properties?

• Has the municipality already incurred any costs to replace or dispose of AFFF?

• Are historical records available?

• Could nearby water systems or private wells be affected?

• Who within the municipality has the best institutional knowledge?

• What funding or cost-recovery options may be available?

These questions do not assume that contamination exists. They help local leaders understand what information may already be available and where additional uncertainty remains.

The Importance of Fire Department Knowledge

Municipal leaders may not know where AFFF was used 10, 20, or 30 years ago. Fire chiefs, retired personnel, and long-serving department staff often do.

They may have knowledge of:

• Where training took place

• How frequently foam was deployed

• Where equipment was cleaned

• Whether unused foam was discharged

• When AFFF products were replaced

• Which properties were involved

• What operational changes have already occurred

That knowledge can be essential when a municipality evaluates potential exposure or considers legal and financial options.

Because institutional memory can disappear as employees retire or records are discarded, municipalities may benefit from documenting this history while knowledgeable personnel are still available.

Why Some Municipalities Are Exploring Litigation

Many public entities are pursuing legal claims against PFAS manufacturers to recover costs tied to contamination and historical AFFF use.

The central argument is straightforward: municipalities and fire departments relied on products that manufacturers marketed as effective and safe, without receiving adequate warnings about their environmental persistence and potential risks.

The ongoing AFFF multidistrict litigation has already produced major settlements for public drinking water systems. Claims involving fire training sites, airports, wastewater systems, landfills, and other publicly owned properties remain active areas of litigation.

For municipalities, legal action may offer a way to seek recovery for costs such as:

• Site investigation

• Environmental consulting

• Monitoring

• Remediation planning

• Disposal of legacy foam

• Equipment replacement

• Future cleanup obligations

• Other contamination-related expenses

These claims are not about assigning blame to firefighters. They focus on whether local taxpayers should bear the financial burden created by products manufactured and sold by companies that had greater knowledge of their risks.

Litigation as Part of a Broader Financial Strategy

Legal action is not a substitute for municipal planning, environmental assessment, or regulatory compliance. It can, however, complement those efforts.

PFAS-related obligations may unfold over many years. Grants or public funding may cover some expenses, but they may not address the full cost of investigation, monitoring, remediation, or long-term property impacts.

For that reason, some municipalities are evaluating litigation as one part of a broader financial strategy designed to:

• Protect local budgets

• Reduce pressure on taxpayers

• Preserve flexibility for future costs

• Hold responsible manufacturers accountable

• Support long-term environmental planning

The earlier a municipality understands its potential exposure, the more options it may preserve.

Starting the Internal Conversation

A municipality does not need to know the full extent of contamination before beginning an internal discussion.

The first step may simply be bringing together the people who understand the property, the department’s historical practices, the municipality’s finances, and the evolving legal landscape.

That conversation may include:

• Fire leadership

• City or county management

• Municipal counsel

• Finance officials

• Public works or environmental staff

• Elected leaders

• Outside legal or technical advisors

The goal is not to create alarm. It is to make sure important information is not overlooked, and potential opportunities are not missed.

Looking Ahead

PFAS contamination linked to historical AFFF use presents a challenge that many municipalities did not create and could not reasonably have anticipated.

Fire departments used these products to protect lives and property. Local governments followed the standards and guidance available at the time. Yet some communities may now face significant costs associated with products whose risks were not fully disclosed.

Municipal leaders are in a position to make sure their communities understand the issue, preserve historical information, evaluate potential financial exposure, and consider every available path for recovering costs.

For municipalities that own fire departments or training facilities that used AFFF, the most important step may be starting that conversation before future obligations become clearer, and more expensive.

If your municipality has questions about historical AFFF use, potential PFAS exposure, or available cost-recovery options, SL Environmental Law Group is available to discuss your specific circumstances.