AWWA: Proposed Lead and Copper Rule significant step forward for public health protection
AWWA is submitting comments today on the proposed Lead and Copper Rule revisions. While AWWA’s full comments touch on many sections of the proposal, CEO David LaFrance highlights some key areas below.
The American Water Works Association (AWWA) believes the proposed Lead and Copper Rule represents a significant step forward for public health protection. AWWA calls on EPA to make a number of important improvements to the proposal and move forward quickly to finalize the rule.
Lead Service Line Inventories and Replacement
More than three years ago, AWWA’s board adopted a statement of public policy calling for the removal of all lead service lines, a primary source of lead in drinking water. Understanding that most lead service lines are at least partially owned by consumers and located on private property, the board recognized this is a tremendous undertaking that would require the “development of collaborative community-based approaches to remove all lead service lines in their entirety.”
The proposed rule significantly advances this goal in at least two ways. First, it requires water utilities of all sizes to develop inventories of lead service lines in their service areas and to share that information with their communities. While this requirement may seem mundane to some, in truth, it is a tremendous catalyst for better protection today and for a future without lead service lines. Consumers who know that they have lead lines connecting their homes to the water system will be more inclined to collaborate with the utility to replace them. Homebuyers will be more inclined to ask that lead lines be replaced before a property is transferred. Local governments and citizens who more fully understand where lead risks exist may be more motivated to collaborate on solutions.
Second, the rule requires water utilities to develop plans to remove all lead service lines in their entirety over time. This is an enormous undertaking that requires an all-hands-on-deck approach in our communities. Water utilities are ready to be leaders in this challenge. However, the removal of all lead service lines cannot be accomplished without a spirit of community collaboration and shared responsibility among water utilities, property owners, manufacturers, state regulators, federal agencies, financing authorities, plumbers, code officials, local government and many others. It will take time, coordination and money. But ultimately, the best way to protect people from lead in water is to remove the sources of lead. The water community stands ready to embark on this next frontier of lead risk reduction.
Schools and Childcare Facilities
AWWA actively encourages its members to assist schools and childcare facilities in identifying and addressing lead in drinking water in their facilities. In October, AWWA joined with EPA in a Memo of Understanding to help schools and childcare facilities investigate and remediate lead problems.
However, the proposed rule departs from this collaborative approach and instead makes water utilities investigators in buildings that are outside their control. AWWA believes the best role for the water utility in school and childcare facilities is as a helpful technical partner and advisor.
The proposed rule revisions appropriately focus a great deal on “corrosion control,” the process through which water utilities adjust water chemistry to prevent lead from service lines or home plumbing from dissolving into water. Corrosion control is at the core of the existing rule and remains critical in minimizing risks of lead in drinking water.
AWWA is recommending that EPA revisit the proposed corrosion control framework and revise its approach so that water systems are better able to take a science-based approach to providing sustainable and robust corrosion control. AWWA is recommending the rule use a “toolbox approach” that allows utilities to evaluate and implement successful corrosion control strategies.
AWWA is committed to working for strong protections today and a future where lead is no longer in contact with the water we drink. The new LCR is an opportunity to build on decades of progress in reducing lead exposure. As EPA pointed out in its 2016 white paper on the LCR revisions, median blood levels for young children have decreased ten-fold since the mid-1970s. The number of the nation’s large drinking water systems exceeding the LCR action level has decreased by over 90 percent since the rule’s initial implementation.
Still, AWWA and the water community are committed to working toward a day when the potential for lead in drinking water is removed from every household and every community. We look forward to working with EPA, our members and everyone with an interest in safe water as the new rule is finalized and implemented.