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ASDWA Submits Comments on Proposed Delays of LCRR Effective and Compliance Dates

Today (4/8), ASDWA submitted comments (below) on EPA’s proposed delays of the effective and compliance dates for the Lead and Copper Rule Revisions (LCRR). ASDWA’s comments focused on three major issues:

  1. The date for the submission of primacy packages must be delayed by the same length of time as the delay of the LCRR effective date (six months).
  2. Any potential additional changes being considered for the LCRR should also result in a January 1st start of LCRR compliance sampling.
  3. A change in the definitions for lead service lines and galvanized service lines, or additional information and guidance is needed to clarify the requirements for water systems so that primacy agencies can provide appropriate oversight.

Additional issues for future comments and/or input to EPA from the primacy agencies will likely arise from EPA’s planned public listening sessions and community and stakeholder roundtables in 2021.

ASDWA Comments on Proposed LCRR Delay 04082021 Final