Final LCRR Published in the Federal Register
The final Lead and Copper Rule Revisions (LCRR) were published in Friday’s (1/15) Federal Register. This rule represents the culmination of a significant amount of work by a broad range of stakeholders to revise the existing 1991 Lead and Copper Rule (LCR). EPA staff deserves credit for getting the LCRR to the finish line.
Today, the real work for LCRR implementation begins. There will be several simultaneous moving parts with LCRR implementation, starting with service line inventories and lead service line (LSL) replacements plans (noting that there are many other critical parts within the LCRR). While there are only nine required data elements for the inventories in the LCRR regulatory language, how to handle unknowns and how much analysis of existing information by the water system is needed for a credible initial inventories are just two of the “gray areas” within the LCRR. ASDWA has developed two white papers on inventories that are a starting point for figuring out some of the inventory issues, but a lot more work by a broad range of stakeholders is needed for the final LCRR to work well across the country.