In more than 150 pages of formal comments submitted to EPA last Saturday, AWWA restated its strong support for replacing all lead service lines across the United States but made clear that portions of the rule are not feasible as written. The public comment period ended February 5, with water systems across the United States contributing their own perspectives. “Over the last several decades, the drinking water community has made tremendous strides in reducing lead levels in drinking water,” AWWA wrote in its comments to EPA. “More can and should be done. The next steps in drinking water policy to further lead risk reduction must be credible, legally sound, truly feasible, and appropriate to the challenge at hand.” (Pictured right, utility worker from City of East Lansing, Michigan, replaces lead service line.) AWWA wrote that EPA’s estimated cost of the rule – between $3 and $4.9 billion annually – is more than any previous regulation under the Safe Drinking Water Act. Estimates for the total number of lead service lines nationwide range from 6 to 10 million. If the cost to remove each line averages about $10,000, the total cost could top $90 billion. “We are concerned that most, if not all, regulated systems will not have the resources needed to meet EPA’s ambitious timeline for lead service line removals,” AWWA wrote. “We are also concerned with the potential impacts on households that cannot afford higher water bills, as increased compliance costs are directly passed on to customers in many cases.” Under the proposed rule, most U.S. water systems would be required to replace all lead service lines within 10 years. “There may be shortages of skilled workers at any given time, particularly in light of a nationwide mandate to perform all of this work during the same 10-year time period,” AWWA wrote. EPA anticipates finalizing the LCRI before the Lead and Copper Rule Revisions (LCRR) compliance begins on Oct. 16, 2024. AWWA commended EPA’s intention to continue with a “treatment technique” to control lead and copper, through which water systems actively manage the corrosivity of the water to minimize the possibility of lead getting into drinking water, rather than attempt to establish a maximum contaminant level at faucets within homes. AWWA challenged EPA’s interpretation of what is “under the control” of water systems as it relates to removing lead service lines on private property. Because ownership of lead service lines is often split between a water system and private property owners, accessing pipes on private property is often a barrier to complete service line removal. AWWA stressed that control “is based on ownership.” The proposed LCRI lowers the Lead Action Level to 10 parts per billion from 15 ppb, introduces a new sampling protocol and changes how sample sites are prioritized. AWWA said these changes will make the action level much harder to consistently achieve and stressed that EPA has not demonstrated that water systems targeted by the rule will be able to consistently comply with the lower action level. “AWWA hopes that these comments will assist EPA as it formulates a final LCRI that achieves additional risk reduction while recognizing the additional resource-intensive challenges facing water systems, including per- and polyfluoroalkyl substances (PFAS), cybersecurity, climate change and aging infrastructure,” AWWA wrote. The proposed LCRI builds on three decades of regulations to minimize the possibility of lead from pipes and plumbing getting into drinking water. The number of the nation’s largest drinking water systems with a 90th percentile sample value exceeding the Lead and Copper Rule (LCR) action level of 15 parts per billion has decreased by more than 90 percent since the initial implementation of the LCR in 1991. An EPA white paper in 2016 on the LCR revisions states that median blood levels for young children have decreased ten-fold since the mid-1970s.