ASDWA & EPA’s LCR Federalism Consultation

The comment period for EPA’s Federalism Consultation on the Lead and Copper Rule (LCR) ends on March 8th. ASDWA’s Board of Directors met on Feb. 13-14 to make a deep dive into the five issues (and other issues) that EPA asked for comments on:

  1. Lead Service Lines (LSLs)
  2. Corrosion Control Treatment (CCT)
  3. Transparency and Public Education
  4. Tap Sampling
  5. Copper

The LCR is probably the most complex drinking water regulation with lots of moving parts, so one of ASDWA’s goals is to simplify the regulatory requirements so that everyone can read and understand them. Keeping many of the regulatory components for sampling sites and monitoring frameworks are avenues for potential simplification. Additionally, a holistic regulatory approach is needed, that considers simultaneous compliance issues with all drinking water regulations and with regulations for wastewater discharges.

ASDWA is also estimating the staff-hours needed to implement the various options that EPA has listed as part of this Consultation, as any LCR option will likely lead to increased workload for states. This increased workload will likely include review & approval of lead service line inventories, review & approval of updated sampling plans, review & approval of updated corrosion control plans, and review & approval of updated public notification and public educations plans. The annual increase in states’ staff-hours will likely be significant.