EPN Comments on Proposed Lead and Copper Rule Revisions

On February 10, 2020, EPN submitted comments in response to EPA’s proposed revisions to the Lead and Copper Rule (LCR). Lead is a highly toxic pollutant that is especially harmful to children. There is no safe level of lead in blood. Lead can damage the central nervous system, cause learning disabilities, behavioral problems, and lower IQs in children, and create other serious health effects, including reproductive problems, in adults. EPN is deeply concerned that the proposed LCR fails to expedite public protection from the harmful effects of lead in drinking water. EPN recommends that EPA consider an option to lower the level at which water systems take action, retain the lead service line annual replacement rate, make requirements much less complex, simplify determinations and enforcement actions taken when systems don’t comply, improve reporting, and clarify the rule’s water sampling language to ensure timely and effective public health protection.

Read a summary of EPN’s comments.

Read EPN’s comments.

EPN also sent a letter to David Ross, Assistant Administrator, EPA Office of Water, regarding the LCR proposed revisions and EPN recommendations. In addition, on March 23, EPN submitted this one-page summary to EPA’s Science Advisory Board for consideration during its March 30 public teleconference.

Read comments of EPN member Jeff Cohen, former EPA Senior Manager, Office of Atmospheric Programs, Office of Air and Radiation.

Read comments of EPN member Joe Cotruvo, former Director, Criteria and Standards Division, EPA Office of Drinking Water

Read comments of EPN member Cynthia Giles, former Assistant Administrator, EPA Office of Enforcement and Compliance Assurance.