ASDWA Releases Costs of States’ Transactions Study (CoSTS) for the Lead and Copper Rule

ASDWA has completed a Costs of States’ Transactions Study (CoSTS) for potential Long-Term Revisions to the Lead and Copper Rule. EPA is in the process of developing and analyzing several regulatory options for the LT-LCR. No matter what regulatory option is ultimately selected, state drinking water agencies will face an increased workload – from tracking what is submitted to reviewing the submission to ensure that it is correct to helping systems revise incorrect submissions to training and technical assistance to compliance and enforcement. And all of these actions add up to a significant number of hours for states that are currently facing budgetary and staffing constraints.

The study estimated that the national total of additional hours would range from 763,954 hours to 1,007,993 hours, depending on the Corrosion Control Treatment (CCT) regulatory option selected. Assuming an average loaded hourly rate of $100 per hour for a state staff person, this translates to an additional burden of $76 million to $100 million annually to states from the LT-LCR. Given the states’ ongoing challenges in meeting EPA’s requirements for the existing drinking water regulations, this is potentially a significant increase in an era of flat funding.