Schedule for OMB Review of Final LCRI Continues to Tighten

EPA plans to finalize the Lead and Copper Rule Improvements (LCRI) by October 16, 2024, to minimize implementation issues with the final Lead and Copper Rule Revisions (LCRR). A significant step for the finalizing the LCRI is a review the Office of Management and Budget (OMB) that typically has a 90-day deadline. As of Friday, July 26th, the final LCRI has not been set to OMB for review, according the OMB website. While the final LCRI is clearly a high priority for the Administration, the final LCRI is not the only regulatory action from the Office of Water (OW) for OMB’s review. Five other OW regulatory actions are currently under review at OMB, and two examples are the Clean Water Effluent Limitation Guidelines and Standards for PFAS Manufactureres that was received by OMB on June 14th and the the Federal Baseline Water Quality Standards for Tribes that was received by OMB on June 21st.

According to the proposed LCRI, the two LCRR components that will remain as is with the final LCRI are the 24-hour Public Notification (PN) for an Action Level Exceedance (ALE) and 30-day customer notification of any lead service lines, galvanized requiring replacement (GRRs) and service lines with an unknown service line material on either the public or private sides. The LCRR regulatory requirement for customer notifications with unknown materials on either side will likely result in millions of customer notifications being sent out, starting on October 17th and then being completed within 30 days. Collectively, due to the high likelihood of unknown materials on the private side of service lines due to lack of records, these notifications will be a significant effort for thousands of water systems.