Lead in Drinking Water
The EPA partnered with community organizations to host a series of virtual roundtable conversations about the proposed revisions to the Federal Lead and Copper Rule. WHE hosted a Pittsburgh Roundtable on June 3, 2021. These revisions will be the first in decades to these requirements that ensure our drinking water is lead-safe. While we celebrate the opportunity to strengthen the rule, the proposed changes fall short in many ways. The EPA is anticipated to release the final Revised Lead and Copper Rule on December 16, 2021.
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|In striving to create health protective standards, the EPA should establish an enforceable maximum contaminant level (MCL)1 and lower the action level to 5 ppb at most.||Health experts agree there is no safe level of exposure to lead.|
Lead Service Line Replacement and Inventory
|Prohibit partial lead line replacements.|
The EPA’s Science Advisory Board noted that partial lead line replacements are “frequently associated with short-term elevated drinking water lead levels for some period of time after replacement, suggesting the potential for harm, rather than benefit during that time period.” According to the CDC, partial replacements “may be linked to increased incidence of high blood level in children.”
Partial lead line replacements, with homeowners often shouldering the cost of the private side replacement, worsen inequity.
|Support all systems, especially small systems or those in low-income communities, rural communities, and communities of color, in identifying lead service lines and creating an inventory prior to reaching trigger level or action level.||Identifying LSLs and developing an inventory upfront allows communities to quickly take action on dangerous lead levels. Any delay in action is very dangerous to children’s health.|
|The order of lead service line replacement must take severity of exposure and historically underserved communities into account for prioritization.||Water equity, environmental justice and ending childhood lead poisoning hinge on addressing exposure in those areas hit hardest by lead poisoning.|
|The Lead and Copper Rule should require that corrosion control optimize the removal of lead (not just stop at the action level).||Health experts agree there is no safe level of exposure to lead. Neither the action level nor the trigger level are health protective standards. Utilities required to use corrosion control treatment need to only reduce lead levels so that fewer than 10% of samples exceed 15 ppb even though we know that any lead level over 0 ppb presents risk. Most utilities stop these efforts to reduce lead levels any further once the required 15 ppb level is reached.|
Ensure the public knows that lead levels are highly variable throughout a system and all individual taps present a possible risk.
Similarly, ensure the public knows how sampling is done for the lead and copper rule, explaining what the results mean for individuals and families.
|Water systems report the 90th percentile value from the lead sampling. This means that any individual tap is not guaranteed to have the reported concentration coming out of its tap. Individuals in both communities that report lead levels below the action level and those that report lead levels about the action level must understand that any individual tap may have unsafe lead levels. Individuals should also have the knowledge and understanding of how the sampling is done.|
|Ensure communication to the public is distributed in laymen’s terms (not in legal jargon). Communication should also be available from the EPA in multiple languages.||In order to give individuals the power and ability to take the steps they see necessary, communication must be easy for the public to understand.|
|The EPA must proactively educate the public on steps they can take to protect their families (such as flushing water and using filters).||Lead poisoning is irreversible, so prevention of exposure is key.|
|Require that all systems create a system for community input (i.e. community advisory board).||Community advisory committees can serve as a more approachable avenue for ratepayer input and increase transparency with the public.|
|Affordability and Funding|
|Ensure water system improvement costs (or lead related costs) are not passed on to rate payers, especially low-income customers.||Water and sanitation affordability is well known to be a key component of water and sanitation access. In developed countries like the United States, a non-negligible group of households experiences limited access to drinking water and sanitation due to affordability problems rather than infrastructural inaccessibility. Moreover, unaffordable water and sanitation poses serious public health, wellbeing, and safety concerns. Thus, affordability must be a central tenet in the revisions of the LCR.|
|Define affordability on a household level, not on a community level.||According to Teodoro (2018), “the conventional approach measures affordability as a community’s average cost of water and sewer service as a percentage of that community’s median household income (%MHI), with values <2.0 or 2.5%—4.0 or 4.5% combined—deemed “affordable.” Originally intended as a means of gauging a community’s overall financial capability for purposes of negotiating regulatory compliance, this standard has been widely misapplied to household affordability. As a result, evaluations of household water and sewer utility affordability are inaccurate at best and misleading at worst.”|
|Utilize federal resources to fund water systems and their improvements.||Federal funding for water systems is essential to preserve affordability.|
|Provide support for water systems and communities to develop a trained workforce, ensuring equitable participation.||The lack of a trained workforce is a major barrier to providing safe, clean, drinking water.|
|Sampling and Filter-First|
|Require sequential sampling,||Long-term sequential sampling can help determine treatment effectiveness on individual lead sources in the home.|
|Adopt a filter-first approach in schools and childcare centers, and require post-installation testing to ensure the filter is working.||Requiring only 5 water samples to be tested in schools and 3 water samples in childcare centers do not tell you enough about the presence of lead in children’s drinking water. There are highly variable results throughout all the outlets in these centers, and there is also lots of variability when outlets are retested. The best way to truly protect the children in these centers from lead is filtering first.|
|Support Specific Populations and Systems|
|Regulate small water systems by giving them the support they need, not by giving them exemptions to the regulations.||People have a basic right to clean, safe water. Exempting small water systems from certain regulations could potentially infringe on this right. Instead of giving small systems a way out of regulations, give them the support they need to comply with all the regulations that ensure safe, clean drinking water.|
|Conduct a full environmental justice analysis to ensure that changes to the lead and copper rule (and all regulations) result in an equitable impact to all communities (prioritizing communities of color and low-income communities).||Many previous and current regulations have both caused and perpetuated inequity. A full environmental justice analysis intentionally seeks to prevent this.|