The American Water Works Association (AWWA) is committed to protecting public health today while we work toward a future when all lead service lines are removed from our communities. We look forward to reviewing EPA’s proposed Lead and Copper Rule Improvements (LCRI) and helping the agency move toward an effective and protective final rule.

AWWA strongly supports EPA’s goal of removing all lead service lines as quickly as feasible from our communities, on both public and private property. We are proud to lift up the examples of many members that have worked swiftly and effectively to address lead line replacement in their communities. We also agree that lead service line inventories should be continually updated so consumers understand where lead risks reside and can make informed decisions to protect their households.

It’s important to recognize that while some communities can move quickly to replace all lead service lines, others need longer time frames. We are pleased that EPA recognizes that a one-size-fits-all approach will not work and is proposing a formula to help systems with large numbers of lead lines in their service areas comply with the rule.

Some communities and their local partners will have to overcome barriers in order to accelerate lead service line replacement and meet EPA’s proposed timeline. For example, not every property owner is amenable to replacing a service line, even when the water system bears partial or full cost. In many states, water systems do not have legal authority to access private property without the owner’s permission and lack clear authority to spend public ratepayer funds to remove lines on private property. In other places, water systems will face logistical challenges as they coordinate lead service line replacement with street improvement projects or incorporate it into large capital projects. Lining up trained contractors in a tight labor market and acquiring necessary materials introduces additional complications. We hope EPA will work closely with state primacy agencies, AWWA, local governments, and water utilities to find workable pathways to overcome these barriers.

Cost will also be a significant challenge in replacing all lead service lines, especially when considered alongside competing priorities such as PFAS removal, cybersecurity upgrades, and other critical infrastructure investments. The average cost to fully replace a single lead service line is more than $10,000, and EPA estimates there are 9.2 million lead lines connecting homes to water systems nationwide. The total cost could easily exceed $90 billion. Even with the unprecedented $15 billion injection for lead service line replacement from the federal Bipartisan Infrastructure Act, water bills will rise to pay for this initiative. Recognizing that many households already struggle to pay their water bills, we look forward to working with EPA and other partners to lessen the cost burden in disadvantaged communities.

Communities nationwide are already working on many fronts to reduce the risk of lead getting into drinking water. They are developing and sharing lead service line inventories, expanding testing in schools and child-care facilities, and communicating actively with consumers about lead. The daily progress builds on more than three decades of corrosion control measures and other risk reduction practices that have reduced lead exposure nationwide. We look forward to working together with EPA, states, and water systems across the country to refine and implement the Lead and Copper Rule for the good of present and future generations.

Established in 1881, the American Water Works Association is the largest nonprofit, scientific and educational association dedicated to managing and treating water, the world’s most vital resource. With approximately 50,000 members, AWWA provides solutions to improve public health, protect the environment, strengthen the economy and enhance our quality of life.

Media Contact

Greg Kail, American Water Works Association, 303-734-3410, [email protected], www.awwa.org

SOURCE American Water Works Association