APWA Submits Comments on Lead and Copper Rule Revision

APWA has submitted comments to the Environmental Protection Agency (EPA) regarding the Agency’s attempt to revise the Lead and Copper Rule (LCR). EPA asked stakeholders at a meeting held in January for comments on potential areas of revision, as well as revisions the Agency had not considered prior to that meeting. You can see the Agency presentation from that meeting here.

The comments center on the fact that the APWA’s membership is committed to reducing lead contamination in our nation’s drinking water. Moreover, our members will work to provide EPA information and expertise on how to best proceed in achieving that goal in all communities, both large and small, rural and urban.
APWA made the following recommendations regarding revisions to the LCR:

  1. Require all systems with known lead service lines, regardless of population served, to install and maintain corrosion control treatment (CCT).
  2. Dedicate additional EPA and other federal funds to providing resources (direct funding, technical assistance, incentives, etc.) to small and disadvantaged systems to help in installing and maintaining CCT.
  3. Make regular evaluation of their CCT a requirement for systems that would be reviewed by the state with primary regulatory authority.
  4. Implement a “sliding scale” for installing CCT, with smaller systems a longer period to install and optimize CCT.
  5. Make completing a full inventory of lead service lines an Agency priority, with the goal of allowing water utilities to use the inventory to assist in replacement of those lines in their service area.

You can read APWA’s comments in full here. The docket for submitting comments can be found here.