AWWA today submitted its formal comments on the proposed changes to the U.S. Environmental Protection Agency’s (EPA) Lead and Copper Rule (LCR). The LCR is an important drinking water regulation, and the proposed revisions are significant in advancing public health protection. Utilities can submit their comments to the EPA via www.regulations.gov to Docket No. EPA-HQ-OW-2017-0300. AWWA issued a press release from David LaFrance that highlights both progress in the LCR and some of AWWA’s recommendations for improvement. Water utilities should also be aware that the U.S. House Subcommittee on Environment and Climate Change has scheduled a Tuesday, Feb. 11, hearing that will likely generate media attention. The 10:30 a.m. ET hearing is titled, 'EPA's Lead and Copper Proposal: Failing to Protect Public Health.' Areas of focus in the formal comments include: Shared responsibility There is broad acknowledgement that the current version of the LCR is difficult to implement since the most significant sources of lead in contact with water occur largely on private property. Addressing lead in drinking water is a shared responsibility among water utilities, property owners, manufacturers, state regulators, federal agencies, financing authorities, plumbers, code officials, local government and many others. It will take time, coordination and money. Optimizing corrosion control The proposed changes to the rule do not provide the necessary flexibility to water systems seeking to balance multiple water quality, operational constraints and environmental factors. This approach unnecessarily prevents EPA, state primacy officials and water systems from using the best available science. AWWA’s comments recommend EPA revisit its requirements for corrosion control in the proposal and incorporate a toolbox approach that clearly articulates criteria for balancing objectives and constraints in selecting appropriate lead corrosion control strategies. Inventories and lead service line replacements AWWA recognizes the need for full lead service line replacement, which begins with a reliable inventory of all lead service lines. A full inventory of lead service lines would increase customer awareness and help organize replacement programs. Lead in schools and childcare facilities The proposed changes to the LCR has water systems inserting themselves in schools and childcare facilities, taking samples for lead testing and reporting results to administrators. AWWA’s comments recommend water systems serve as a partner communicating the need for and advancing strategies to reduce lead exposure to children in their care. AWWA prepared the following resources to assist individual water systems interested in preparing comments on the proposal prior to the Feb. 12 deadline: Model letter – A template for drafting a comment letter on the proposed revisions Major themes – A brief overview of major issues within the proposed rule and themes AWWA will emphasize in its comments with respect to these issues Resource list – A short list of readily available AWWA and EPA references relevant to the proposal Please direct questions to Steve Via , AWWA’s director of federal relations.