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On December 13, AMWA submitted comments to EPA as it considers further revisions to the Lead and Copper Rule. These revisions, referred to as the Lead and Copper Rule Improvements (LCRI), may seek to impose requirements that would replace all lead service lines (LSLs) as quickly as possible. The letter urged EPA to make minimal changes to the rule, arguing that the agency should use data collected over the next several years on LCR Revisions (LCRR) implementation to make revisions during the next Six-Year-Review.

In the comments, AMWA asked the EPA to recognize, consider, and address the potential hurdles associated with full LSL replacements should they be mandated as part of a proposed LCRI rule, and to provide support for community water systems to address these challenges. AMWA reiterated its support for individual utility efforts to remove their LSLs as quickly as possible and agrees that the complete removal of LSLs should be the ultimate goal but has reservations about a firm deadline.

Recently, EPA Assistant Administrator for Water, Radhika Fox, announced that EPA intends to propose the LCRI in September of 2023. EPA insists the LCRI will be finalized before the October 2024 compliance date of the LCRR.