The Association of Metropolitan Water Agencies (AMWA) submitted comprehensive comments on the Environmental Protection Agency’s (EPA) proposed National Primary Drinking Water Regulations: Lead and Copper Rule Improvements (LCRI). AMWA’s comments acknowledge the consideration EPA has put into addressing the complex challenge of reducing lead exposure in drinking water; however, the association emphasizes the importance of a nuanced and practical approach to the proposed revisions.
AMWA aligns wholeheartedly with EPA’s objective to swiftly identify, remove, and replace lead service lines and agrees that completely removing all lead service lines is the ultimate goal. AMWA appreciates EPA’s acknowledgment that this objective may not be universally attainable for every water system in the timeframe specified in the proposal and that access to the private side of the service line could be a barrier.
Noteworthy concerns raised by AMWA include the potential implications of the proposed rule on private property access, funding challenges, and the substantial public notification requirements, which may disrupt ongoing lead service line replacement programs. AMWA emphasizes the need for a balanced communication strategy to prevent public confusion and maintain trust in water systems actively engaged in replacement initiatives.
Additionally, AMWA draws attention to the unique circumstances of diverse water systems and cautions against relying solely on anecdotal examples that may not represent the broader challenges facing the nation’s water utilities. The association also underscores the financial realities of publicly owned water systems, highlighting the disproportionate impact of increased costs on low-income communities.
“Providing safe and reliable drinking water remains the highest priority of AMWA members. In the case of the LCRI, addressing the critical issue of lead exposure is important but must be balanced with a pragmatic rule that water systems can implement successfully,” said AMWA CEO Tom Dobbins. “We urge EPA to consider AMWA’s recommendations to build a more achievable, practical, and enforceable rule. Our commitment lies in finding effective solutions that safeguard public health and prioritize the needs of the communities we serve.”
EPA must promulgate the LCRI prior to the October 16, 2024, Lead and Copper Rule Revisions compliance date to avoid a scenario where water systems invest valuable resources in complying with provisions that the LCRI subsequently deems irrelevant.
