The American Water Works Association (AWWA) on Saturday submitted its comments to the U.S. Environmental Protection Agency (EPA) regarding the proposed Lead and Copper Rule Improvements (LCRI). Public comments are due to EPA today. In a press release , AWWA reaffirmed its support for the removal of lead service lines nationwide while recommending critical revisions to make the rule feasible to implement and affordable for communities. AWWA noted in its comments that “Over the last several decades, the drinking water community has made tremendous strides in reducing lead levels in drinking water. 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.” AWWA’s comments support several different aspects of the proposal, including: The complete removal of lead service lines over time, in their entirety (although AWWA expressed strong concern about EPA’s proposed timeline.) Retaining the treatment technique regulatory framework for the control of lead and copper in drinking water. Delaying implementation of many aspects of the Lead and Copper Rule Revisions (LCRR) such as changes in requirements for monitoring, public education, sampling in schools, and associated reporting so that work can proceed in an organized and efficient manner. Recognizing the importance of simplifying the rule to facilitate correct and effective implementation. AWWA also raised several concerns, including: The proposed LCRI inaccurately equates community water systems having “access” to private property with a system having “control” over the service line on private property as described in the Safe Drinking Water Act (SDWA). The proposed LCRI asserts without demonstration in the record that the rule is feasible as proposed. Particularly, EPA has not demonstrated the feasibility of: Replacing all lead and galvanized requiring replacement service lines within 10 years without substantial and currently unavailable federal subsidies and Lowering the lead action level to 10 µg/L, while also substantially altering the dataset on which the lead action level exceedance is determined AWWA encourages members to be prepared to respond to media inquiries as the public comment period closes and to proactively communicate with the communities you serve about what your water system is doing to address lead exposure. The LCRI proposal presents an opportunity for utilities to strengthen public trust by talking about their efforts to protect people from lead. Utilities are encouraged to discuss: Your understanding of consumers’ concern about lead and your commitment to protecting public health. The progress being made in your community in identifying lead service lines (and galvanized requiring replacement). The broader historical progress on reducing lead risks in your community from water and other sources. What steps your community is taking to support lead service line replacement and any impediments you are facing. Your commitment to ongoing communications about lead in water. AWWA has resources to help utilities communicate about lead in drinking water: Lead Resource page Lead Communications Guide and Toolkit DrinkTap’s Lead in Water consumer page AWWA’s “ Together, let’s get the lead out ” animation AWWA also offers Trending in an Instant: A Risk Communications Guide for Water Utilities to assist in those situations. Questions can be directed to Steve Via , federal relations director, or Greg Kail , director of communications.