Protecting water resources and the environment has been Woodard & Curran’s main goal since our founding on the heels of the Clean Water Act. As we mark the 10th anniversary of Imagine a Day Without Water, we are actively helping water suppliers coast to coast ensure Americans have access to safe, clean drinking water. This includes helping public water agencies meet regulatory compliance, such as the Environmental Protection Agency’s Lead & Copper Rule Revisions (LCRR) promulgated in January 2021.
Under the LCRR, drinking water utilities were tasked with creating an inventory of service lines and developing a lead service line (LSL) replacement plan to submit to the EPA by October 16, 2024. This has been a significant undertaking for many communities and the work is not over. In addition to enhanced testing and more stringent and rapid public notification requirements, these agencies need to roll out their replacement plans and communicate the effort to their customers. The LCRR closes a loophole that existed under prior laws, requiring water systems to replace at least 3 percent of LSLs annually if more than 10 percent of sampling results exceed the actionable level of 15 parts per billion (ppb). The goal of this measure is to ultimately remove all LSLs nationwide to ensure public health and safety regardless of lead levels.
Earlier this month, the Biden-Harris Administration issued the Lead and Copper Rule Improvements (LCRI), which requires LSL replacement within ten years. This measure also mandates drinking water suppliers with known LSLs to collect and analyze the first and fifth liter of water samples collected at the tap, using the higher of two values when determining compliance with the rule. Furthermore, it reduces the lead action level from 15 ppb to 10 ppb. If samples exceed 10 ppb, agencies must notify their customers and take action to reduce lead exposure, while working to replace the LSL or incorporate corrosion control treatment to reduce lead that leaches into drinking water.
