The National Drinking Water Advisory Council (NDWAC) Lead and Copper Working Group held its sixth in-person meeting on April 23 and 24 to discuss potential revisions to the Lead and Copper Rule (LCR). During this meeting, working group review and deliberation focused on a second draft recommendations document outlining potential LCR revisions for the full NDWAC to consider before passing them on to EPA.
The second draft recommendations document includes substantial revisions from the first “strawman” draft and reflects substantial progress toward reaching consensus on several individual issues. The problem, however, is that even though there is significant agreement on how to make any individual piece of a new LCR construct work more effectively and/or efficiently, it is not clear how all the pieces will fit together as a cohesive whole.
Potential implementation issues are now coming to the forefront of considerations. Promulgation of all of the more stringent individual recommendations currently on the table is not feasible and, taken together, would strain already tight state, local and utility budgets. Arriving at recommendations for a revised LCR that enhances public health protection while remaining implementable from both a technical and financial perspective will require trade-offs between recommendations for revising individual components within the rule.
At the core of the trade-off debate, are the resources that would be required to move toward a more proactive lead line identification and replacement program. Implementation of such a program will require reallocation of resources from other rule-related activities that are less efficient and effective in reducing overall lead exposure. As of the end of the last meeting, it is not clear where (or if) there will be consensus on the trade-offs that will be accepted and recommended by the working group.
One more in-person working group meeting will be held in June to try to reach consensus on recommendations and finalize the draft report for full NDWAC review. AMWA member Robert Steidel, City of Richmond Virginia Director of Utilities, serves as a member of the NDWAC working group reviewing potential revisions to the LCR. Members of the AMWA staff are also attending all meetings, will continue to provide updates on the process and are available to answer any questions you may have on this process.