Water utilities must prepare now for 24-hour lead notification requirement

With only seven months until compliance deadlines for key elements of the revised Lead and Copper Rule, drinking water utilities must prepare to communicate effectively – and in some cases, immediately – with their communities.

The Lead and Copper Rule Revisions (LCRR) require communitywide public notification within 24 hours of a Lead Action Level exceedance. In addition, new sampling protocols and a lower action level is likely to push many more utilities into situations where they are exceeding the action level.

Stephen Estes-Smargiassi, chair of AWWA’s Lead and Copper Rule Advisory Committee, is urging utilities to communicate now with public officials, media, and other stakeholders to inform them of the changes. Proactive engagement can be the difference between strengthening or losing public trust in the community. In a video interview (pictured at right) with AWWA Communications Director Greg Kail, Estes-Smargiassi pointed out that the new public notification requirement is for the entire community – not just homes with lead service lines.

“You’re going to need to do a 24-hour public notice,” he said. “It’s to everybody in your community, public media, newspaper, television, radio and it’s to everyone. So why is that important? Well, we know that the folks we’re really trying to reach are folks who have the higher risk, those with the lead service lines. But our messaging under the rule is to everyone.”

Estes-Smargiassi recommends utilities proactively reach out to various stakeholders in their communities before beginning the sampling process.

“You have to be prepared by working with your local health officials, your risk management people in town. I would personally say make sure the mayor knows before you start sampling, because you don’t want to be surprised and have to do this in a hurry. If you’re not well-organized, if everybody who’s going to be receiving calls doesn’t know about it in advance.”

Estes-Smargiassi, who is the director of planning and sustainability for the Massachusetts Water Resources Authority, discussed AWWA’s recent formal comments on the proposed LCRI, including:

• Oct. 16 deadline to submit lead service line inventory
  • The inventory must include lead lines, galvanized lines requiring replacement and unknown materials
• 10-year window for utilities to replace all lead service lines
  • The difficulty that the cost of this would entail
• Utilities working with homeowners to remove lead service lines on private property

The first step for utilities is an initial inventory of all its service lines.

“That’s due soon,” Estes-Smargiassi said. “If you’re not already working on it, it’s not too late, but you better get hustling because that’s a regulatory requirement. It’s a violation if you don’t submit it by October 16.”

More information about lead service line replacement and other lead-related requirements are available on AWWA’s lead resource page and the lead communications page, including the Lead Communications Guide and Toolkit.