Comment Letter: Lead and Copper Rule Improvements Guidance for Lead Service Line Inventories and Access
EPA released two Lead and Copper Rule Improvements (LCRI) guidance documents to help water systems navigate key implementation challenges:
Overall, we appreciate EPA’s effort to provide additional flexibility, particularly for data-poor and under-resourced systems struggling to complete inventories. However, proposed flexibilities related to accessing private property risk severely undermining the rule by enabling delays and increasing the likelihood of partial replacements.
We encourage EPA to maintain its commitment to eliminating LSLs by adopting guidance that emphasizes solutions and provides clear pathways for full replacement, rather than creating avenues for delay or mechanisms that allow systems to avoid full replacement.
In summary, EPIC’s comments:
Support EPA’s efforts to expand flexibility in inventory development, including the use of predictive modeling and alternative data sources, but recommend additional guidance to ensure data quality and model reliability.
Support the expanded definition of galvanized requiring replacement, which addresses real data limitations and improves access to Drinking Water State Revolving Fund funding.
Raise concerns that proposed access-related flexibilities could weaken LCRI implementation by enabling partial replacements and delaying timelines.
Recommend narrowing the definition of “access barriers,” aligning guidance language with the rule, and removing provisions—such as cost-sharing and certain legal or policy-based exemptions—that could allow systems to avoid full replacement requirements.
Highlight real-world examples of state and local policies that successfully reduce access barriers and accelerate replacement.
