The working group of the National Drinking Water Advisory Council (NDWAC) established to review potential revisions to the Lead and Copper Rule (LCR) will hold its next in-person meeting on February 5 and 6 in Arlington, VA. Previous meetings and webinars have featured in-depth presentations and discussions centered on various requirements the LCR and potential revisions that could be implemented. Now that the major issues have had their initial vetting, the February meeting will focus on a first draft of actual recommendations that the workgroup will eventually forward to the full NDWAC for consideration. The draft document is not yet available for public review, but some of the key issues that will garner further debate are fairly clear based on previous discussions.
Lead service line replacement, the topic of the last meeting of the NDWAC workgroup in November of last year, is perhaps the most difficult issue for reaching consensus on a path forward. Despite a general agreement within the workgroup that removal of all lead service lines is the ideal way to eliminate lead problems, the practical limitations related to cost of replacement and legal responsibility for the residential portion of the water line will remain sticking points in the debate. How far any recommendations go towards mandatory replacement of service lines will bear close watching as the process moves forward.
Potential revisions to other parts of the LCR under consideration for revision are generally less contentious than the service line replacement issue, but, like all regulatory issues, the devil is often in the details. Many suggested revisions to corrosion control requirements, sampling procedures, public education protocols and the overall treatment of copper in the regulation make theoretical sense, but more detailed analyses will be required before many drinking water utilities will be comfortable with endorsing any changes.
With more detailed suggested revisions emerging as part of the draft workgroup recommendations, utilities will be in a better position to evaluate the potential impacts. For those interested in looking closer at the issues, workgroup notices and materials are publically available and normally posted on the NDWAC Lead and Copper Rule Working Group web page. For those interested in a more direct discussion of potential LCR revisions, and the NDWAC process in particular, AMWA will be conducting an interactive panel discussion with NDWAC utility representatives and EPA officials during the 2015 Water Policy Conference.
AMWA member Robert Steidel, City of Richmond Virginia Director of Utilities, continues as a member of the NDWAC workgroup reviewing potential revisions to the LCR. AMWA staff is also attending all meetings and will continue to provide updates on the process.