Author: Sophia Rappazzo

The Unfinished Cleanup: PFAS in the Anacostia 

Rivers running around Washington, D.C. are no stranger to contamination. Aging combined sewer systems routinely dump wastewater into local waterways through discharges known as combined sewage overflows, while legacy pollution from past military activities pollute the water as well, particularly in the Anacostia. D.C.’s agencies have evolved to address the environmental stressors of sewage and industrial pollutants like polychlorinated biphenyls (PCBs), but certain industrial pollutants remain unaddressed. 

The Anacostia River Park, which borders the Anacostia River, is a Superfund site (a contaminated site listed under CERCLA’s National Priority List for cleanup) due to chemical dumping associated with former U.S. military activities. The river itself contains remnants of this cheap dumping practice that has harmed generations of primarily communities of color living by and off the river, from playing in its river banks to consuming its fish. After over 150 years of dumping toxic waste into the river, the Office of the Attorney General of the District of Columbia sued the U.S. government in early 2025 under CERCLA and the Brownfield Act. OAG alleged that the dumping was an intentional act of noncompliance with environmental laws, seeking “costs, damages, and a declaration of future liability” against the government. 

D.C.’s Department of Energy and the Environment (DOEE) initiated the Anacostia River Sediment Project to clean up the river’s contamination in 2013, culminating in the release of the 100% Design Report in the summer of 2025. The report outlines the remedial design with considerations such as the feasibility, cost, and benefits of certain remediation design options, factoring in stakeholder input. While the report is a milestone in clean up efforts and is partially funded by entities like Pepco who contributed to its pollution, it is largely aimed at PCB contamination, leaving out other contaminants like PFAS which have been documented to reside in the Anacostia watershed. In line with the report, D.C.’s OAG alleged that the river contained PCBs and other industrial contaminants such as heavy metals, notably leaving out any mention of PFAS – which in some regards, may be the most insidious pollutant in the river due to their persistent, bioaccumulative nature. However, the District’s 2023 suit against major chemical corporations like 3M acknowledges that corporations and the DOD used and released products containing PFAS into the river; establishing an understanding of PFAS contamination.

Per- and polyfluoroalkyl substances, or PFAS, are a class of highly persistent, stable, and health-harming chemicals that have evaded substantive national and global regulation for decades. This regulatory ‘hole’ has been permitted via a lack of governmental oversight, systemic failures to hold corporations accountable for dumping, and improper corporate disclosures as to the toxicity of the chemicals. PFAS have been shown to cause a myriad of health conditions, from increased cholesterol to developmental effects to cancer. The exposure pathways of PFAS are well documented, where the chemicals can impact humans via dermal exposure, ingestion, and inhalation and often travel through industrial discharges into bodies of water as exceptionally mobile, stable compounds. The chemicals then bioaccumulate in various ecosystems, meaning that seafood in water bodies contaminated by PFAS are unsafe to consume. DOEE’s fishing advisory issued in 2024 highlights this fact and advises the public not to eat eel, carp, striped bass, or largemouth bass caught in the Anacostia due to high PFAS levels and to instead opt for smaller fish containing less PFAS in their tissues. Maryland’s Department of the Environment similarly issued a fishing advisory for the watershed for PFAS contamination.

The chemicals as both a class and individually are not yet adequately addressed in our drinking water, let alone our water bodies. With the U.S. EPA setting back its PFAS drinking water regulations at the dawn of the second Trump Administration, it is no surprise that water bodies and water quality are not a focus in the PFAS space. There is no government attempt to remediate PFAS in the Anacostia River as there is for PCB and other harsh contaminants, but the chemicals are present. OAG’s 2023 natural resource damages complaint against chemical manufacturers, seeking monetary damages, states that “PFOA and/or PFOS were detected at all locations tested” in D.C.’s waterways. 

The Anacostia Riverkeeper found 8-10 different PFAS chemicals in the six samples collected from the river. The measurable PFOA (a common, “long chain” PFAS compound) concentrations in the samples ranged from 3.5-8 ppt, despite the EPA’s advisory limit of 0.004 ppt, and PFOS (another long chain PFAS compound) concentrations similarly ranged from 4.7-7.7 ppt, exceeding the EPA’s PFOS advisory limit of 0.002 ppt. Furthermore, the Environmental Working Group took water samples at certain locations across the U.S. and found significant levels of PFAS in samples from the Joint Base Anacostia–Bolling military installation situation along the Anacostia. For instance, one sample taken from the base was discovered to have a combined value of 10.6 ppt of the two “short-chain” PFAS (PFHxA and PFPeA) measured in the study. 

Demonstrating the urgency of the public health issue and the recognized presence of PFAS in the river, the Anacostia Riverkeeper submitted public comments to DOEE to its “Early Action Area Remedial Design Report” at the 90% design phase, urging the agency to incorporate remediation plans for PFAS in its 100% Design Report. The Riverkeeper noted that it was “irresponsible for [DOEE] to know there is PFAS contamination in the Anacostia River but to not consider it in [the] [remediation], potentially yielding a final product that is already outdated before it’s even constructed.” The agency responded that it was infeasible at that point in the project because PFAS samples were not incorporated into the plan and “revisions would delay the project by years.”

Given budgetary limitations, the decision to exclude PFAS from river remediation efforts is a multi-pronged determination based on cost, time, resources, and practicality. PFAS are notoriously difficult and costly to filter from water (although there are emerging more cost-effective techniques) and now local governments and utility companies are made to grapple with federal and corporate failures. The argument that the addition of PFAS into the plan would significantly alter a nearly decades-long remediation planning process has merits, but at the same time, PFAS remediation should become a priority for federal and local governments to protect human and ecological health. This is especially pertinent following the allegations in the District’s natural resource damages complaint. 

Although drinking water regulations are likely the first step, addressing the Anacostia’s PFAS contamination in some capacity should be made part of D.C.’s plan to remediate the river. This effort is necessary to safeguard the health of the communities that rely on and live by the river. It would also be a showing to other governments that water quality remediation includes PFAS – contaminants that have been ignored for far too long to the detriment of our health.

The ‘Elder’ Medical-Legal Partnership and Caregiving from an Interdisciplinary Lens

New frameworks, interdisciplinary collaborations, and models of health care may need to emerge to address the impending “caregiving crisis,” or growing strain on the elder caregiving workforce with our aging population. The medical-legal partnership (MLP) model is one potential approach in addressing elder well-being, health, and the caregiving crisis. Medical legal partnerships are an established interdisciplinary framework, combining the legal and medical worlds to holistically serve a population’s needs. Within MLP clinical sites, attorneys are placed directly onsite to work with healthcare providers in identifying and remedying health-harming legal needs.

The model is based on the understanding that health issues are seldom solvable by addressing medical needs. For instance, an elder patient and their caregiver may need assistance in accessing incapacity plans or safe housing for an elder at risk for falls at home. By utilizing the MLP model, clinics can assist older adults and caregivers in navigating the multidimensional, overlapping legal and health issues that elders face, potentially reducing some of the burden on the caregiving population. Addressing common elder issues in one clinic with the expertise of two professions can help streamline access to other resources like public benefits, support the dignity and autonomy of elders, and address a variety of unmet financial, housing and legal needs. The MLP can also assist with the fact that elders have specific barriers to legal and healthcare related to mobility, transportation, and isolation by acting as a “one stop shop” for holistic support. Contributors to elder law also point out that medical providers and attorneys are well-positioned to collaborate so that providers can identify elder abuse.

While MLPs have become increasingly popular, they have scarcely been tailored to elder populations. The Medical-Legal Partnership for Seniors (MLPS) in San-Francisco, a law school clinic that trains medical providers on the legal needs of elders, is one example of an MLP tailored to the elder populations. But for the most part, MLPs have been utilized at the pediatric level where pediatricians are trained to identify the causes of their patient’s health conditions, which often stem from social determinants of health (SDOH) like poor housing conditions. Research has suggested that SDOHs are more important to individual health than genetic predisposition, where SDOHs such as socioeconomic resources, working conditions, housing, environment, race, and gender may be “fundamental causes” of health outcomes. These same SDOHs shape elder health, independence, and overall wellbeing, where intersecting factors and elder social identities may compound poor legal and health outcomes for elders. For example, a low income, older woman of color experiencing housing instability may face intersecting barriers that healthcare nor legal interventions alone can adequately address. Recognizing this, MLP interventions should be multi-pronged to address underlying social factors like structural racism and critically assess their own role in reinforcing systemic inequities. Elders are not a monolithic group, and ‘non-essentializing’ this population is critical in delivering equitable care.

Overall, the MLP framework could be more widely utilized to benefit the elder population and promote their health and justice. Having stronger societal supports like numerous MLPs tailored to elder needs may furthermore assist incrementally in the caregiving crisis, given that elder issues are only becoming increasingly relevant as our population continues to age. The MLP model thus may be a promising method to expand on caregiver and elder supports in the United States.

The Need to Improve and Enforce Digital Accessibility for Telehealth Patients

Telehealth, health care through technological services, has been an increasingly used form of care since the COVID-19 pandemic when digital health care became increasingly necessary to limit in-person interactions. Telehealth is conducted completely online and, therefore, has the potential to be revolutionary for disabled folks who would benefit from the convenience of a digital platform. The digital aspect of telehealth would allow patients to avoid barriers to accessibility that come with in-person appointments, such as issues like transportation and mobility or the need to avoid potential exposure to communicable diseases.

While patients could avoid the barriers to in-person care through telehealth, telehealth has proven to come with digital barriers of its own, largely stemming from a lack of digital accessibility. Telehealth, in theory, would expand access to health care for disabled individuals. In practice, telehealth has not realized its potential because of the inequities associated with online access, such as website inaccessibility. This has resulted in an increasingly inequitable healthcare landscape, where disabled people continue to bear the brunt of systemic inaccessibility. The health care costs are higher for disabled folks with intersecting identities, whereas disabled Black and Latino folks are more likely to suffer from poor health outcomes.

Telehealth is usually inaccessible for several reasons that the Department of Justice (DOJ) has outlined, including poor color contrast, use of color alone to give information, lack of text alternatives on images, no video captions, inaccessible online forms, and mouse-only navigation. In an age where access to information and health services is a health determinant, inaccessible internet access is unacceptable. Digital accessibility is a civil rights issue.

While the Americans with Disabilities Act (ADA) does not explicitly discuss digital accessibility, courts have interpreted Title II of the ADA, a section on discrimination based on disability by state and local governments, to include protecting digital accessibility. This precedent supports protecting digital accessibility for government healthcare agencies. Despite this precedent, legislative action should establish enforceable website accessibility requirements under Title II.

Title III of the ADA, which discusses private businesses and public accommodations, is less resolved when it comes to its protections on website accessibility, creating a lack of uniform protections. Some courts have held that telehealth platforms are places of accommodation, meaning that they fall under ADA requirements of protection, but others have found that they do not qualify. Protections for disabled folks are therefore different by location and private telehealth services can have digital accessibility barriers without consequence. Because Title III lacks enforceable digital accessibility standards, these barriers remain unaddressed.

Given that telehealth is an increasingly relevant mode of healthcare, we should advocate for improved access to its services for everyone by enshrining digital accessibility into the ADA. The exclusion of disabled folks through digital barriers is unacceptable when they are a group that could benefit the most from its benefits. Disabled folks already disproportionately receive less health care because many are disproportionately below the poverty line, making payment impossible, and face issues with accessible in-person services, transportation, and communication. Making healthcare access more difficult by not improving accessibility in all spaces, including digital spaces, leads to more negative outcomes for disabled people, especially for disabled people with intersecting identities. Without stronger enforcement of compliance with digital accessibility guidelines, disabled patients will continue to face digital barriers to healthcare.