AMWA Provides Feedback To EPA On LCRI Guidance Documents

On April 30, AMWA provided feedback on two draft EPA documents related to implementation of the 2024 Lead and Copper Rule Improvements (LCRI). AMWA’s comment letter provides feedback to EPA on helpful information, additional questions, and suggest examples EPA could add to the documents to provide further clarity to water systems and primacy agencies. The draft documents are accessible on EPA’s LCR tools webpage, along with other guidance documents, fact sheets, public notification, and other information that EPA has released to help states and water utilities implement the LCRI.

The first document, LCRI Access Tips, aims to provide information to public water systems to consider as systems determine if they have “access” under the regulation. The LCRI requires water systems to replace all lead and galvanized requiring replacement service lines under the “control” of the water system unless a replacement would leave in place a partial lead service line by December 31, 2037. Importantly, the LCRI does not determine whether a water system has control or access. AMWA’s comments focused on potential clarifying improvements to the guidance’s language and additional questions or examples of barriers to accessing a lead service line.

The second document, LCRI Service Line Inventory Tips, aims to provide information to water systems on methods that water systems can use to complete or inform lead service line inventories, replacement requirements for galvanized requiring replacement lines, and other flexibilities in the rule. Building on the initial inventory water systems were required to submit by October 2024, the LCRI requires water systems to prepare a Baseline Inventory by November 1, 2027 that updates the initial inventory and annual inventories thereafter. AMWA’s comments expressed appreciation for clarifying the use of water system personnel, artificial intelligence tools, and validation flexibilities as methods of completing lead service line inventories. The comments also raised additional questions for EPA to address in final or other related guidance.