Science Advisory Board Drafts LCRR Feedback to EPA

In a draft report discussed at a May 11th teleconference meeting, EPA’s Science Advisory Board (SAB) is providing additional feedback on EPA’s proposed Lead and Copper Rule Revisions (LCRR), expected to be finalized later this year. Highlights from the SAB report include:

  • Request for EPA eliminate the proposed Trigger Level and instead lower the Lead Action Level to 10 micrograms per liter in order to reduce confusion and streamline the rule.
  • Recommendation that LCRR clearly state the lead sampling objectives,  “If the overall objective is to collect water that represents the highest possible lead levels to which a resident might be exposed, then the Proposed Rule should indicate how the sampling protocol will achieve this by obtaining representative samples from the lead service line, premise plumbing, or both.”
  • Determination that the benefit-cost analysis underestimates the benefits of reduced levels of lead in drinking water by focusing on impacts to children and childhood IQ. The SBA argues that including impacts to adults, such as cardiovascular effects, neurological effects, and cancer, in the benefit-cost analysis would increase support for expedited lead service line replacement.
  • Several recommendation to improve the public education and risk communication requirements in the Rule, including a recommendation that EPA develop a centralized portal to disseminate information on the Proposed Rule, training courses for states and utilities, and best practices for implementation.

The draft report can be accessed here. The SAB is making edits to draft based on the May 11th call and will then finalize the recommendations for submission to EPA.