How to comment:
- Review the comments prepared by Indivisible Montgomery (below)
- Go to https://www.regulations.gov/docket?D=EPA-HQ-OW-2017-0300
- Click the “Comment Now” button near the top right of the page
- Enter your comments in the text box; feel free to copy ours or write your own
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Comment Text (for copy/paste into comment field)
Submitted by Indivisible Montgomery, a grassroots organization of nearly 1,700 concerned citizens of Maryland.
There is no safe level of lead exposure, yet outdated and faulty water delivery systems continue to expose millions of U.S. residents to lead in their drinking water. EPA has stated the need to modernize and improve the existing Lead and Copper Rule to increase public protections against the dangers posed by lead in drinking water in communities throughout the U.S. (1,2). The proposed revisions focus on a variety of factors including identification of lead in drinking water, methods of implementation of protective or corrective actions, replacement of lead service lines (LSLs) bringing water into homes, schools and day care centers, and notification and education of the public on appropriate actions to take.
As stated by the EPA and other organizations, the primary problem with lead contamination in drinking water lies with the estimated 6 million LSLs bringing contaminated water to residents of the U.S. (2,3). The proposed rule, however, would actually slow the replacement of lead-contaminated LSLs and thus increase the time frame over which residents could, and likely would, be exposed to lead (4). The existing rule calls for 7% of LSLs to be replaced annually in community water systems if lead measurements reach EPA’s Action Level of >15 ppb. In contrast, the new rule calls for only 3% of LSLs to be replaced when >15 ppb lead is found. This change would effectively more than double the time for replacing offending LSLs for a given water system. A separate assessment by the Natural Resources Defense Council estimated that replacement of all LSLs could take 13 years under the existing rule, but up to 33 years under the revision (5). This assessment called for setting a maximum of 10 years to replace all LSLs nationwide. The American water industry believes that locating and removing all LSLs is urgently necessary (2,5). We agree that achieving this within 10 years is a worthy goal.
It is disconcerting that EPA has chosen not to decrease its Action Level of 15 ppb lead in drinking water. Although EPA has proposed decreasing the Trigger Level to 10 ppb (the level at which water systems must develop plans for the possible reaching of the 15 ppb Action Level in the future), the World Health Organization has stated that 10 ppb is not safe for the most vulnerable, notably children and pregnant mothers and their fetuses (2,5). Moreover, Canada has recently reduced its allowable lead level at the tap, its maximum contaminant level (MCL), to 5 ppb, and Europe has recommended reducing its MCL from 10 to 5 ppb. The NRDC has urged the EPA to lower its lead Action Level to 5 ppm (5). We strongly support this change.
The singular reason for reducing allowable lead concentrations in water now is to prevent exposure to lead, rather than wait for elevated lead to be detected and then for remedial actions to be instituted (5). Remedial actions take time. LSLs are removed only when such remedial actions are ineffective in reducing lead sufficiently. People are exposed in the meantime. The effects of these exposures can last a lifetime (6).
It is widely accepted that there is no safe level of exposure to lead. Yet, over the years 2015-2018, an estimated 5.5 million U.S. residents were served by water systems exceeding the 15 ppm Action Level, and an estimated 30 million residents received water from systems that were in violation of the LCR in a variety of ways. It is time to prevent another generation of children from growing up drinking lead contaminated water in their homes and schools (2,4).
(5) www.nrdc.org/media/2019/191010; www.nrdc.org/experts/erik-d-olson/heres-whats-needed-fix-outdated-epa-lead-tap-water-rule
(6) CDC’s Morbidity and Mortality Weekly Report August 10, 2012, 61(04): 1-9.
(7) Lead Poisoning, Annual Review of Medicine, 55: 209-222, 2004