ASDWA Submits Detailed Comments on Lead and Copper Rule (LCR)
On March 8th, ASDWA submitted detailed comments to EPA as part of the Agency’s Federalism Consultation for the Lead and Copper Rule. These comments were developed by the ASDWA Board based on the questions posed by EPA at its initial meeting on January 8th, but also recommended that the Agency consider using a “bins” regulatory approach with progressively more stringent “bins” with required actions by water systems based on increasing levels of the 90th percentile of lead samples from 1-liter first draw samples.
ASDWA’s comments included a Costs of States’ Transactions Study (CoSTS) that concluded that the impacts on state workloads would be significant. CoSTS estimated more than 730,000 hours annually for implementation of the Long-Term Revisions to the Lead and Copper Rule (LT-LCR), which translates to $73-$97 million annually for states, depending on the regulatory option selected.
