Advocacy Raises Multiple Concerns Over Lead and Copper Rule Improvements

On December 6, 2023, the U.S. Environmental Protection Agency (EPA) published a proposed rule revising the National Primary Drinking Water Regulation for lead and copper under the Safe Drinking Water Act.

Specifically, the proposal requires water systems to replace lead service lines within 10 years, remove the lead trigger level, reduce the lead action level to 0.010 mg/L, and strengthen tap sampling procedures. The proposed rule also addresses the following areas: corrosion control treatment, public education and consumer awareness, requirements for small systems, and sampling in schools and child-care facilities.

The Office of Advocacy filed comments on the proposed Lead and Copper Rule Improvements (LCRI) (PDF, 93.9 KB) on February 5, 2024. Advocacy raised concerns about the rule’s cost and implementation requirements. Specific issues raised by Advocacy include:

  • Federal funding sources cited by the EPA will not be sufficient for small entities to cover the LCRI’s costs.
  • Small entities will encounter significant obstacles to accessing federal funds available for LCRI compliance.
  • Federal funds cited for LCRI compliance are also needed for complying with multiple other federal regulations.
  • Small systems may ultimately pass the costs of the LCRI on to the communities they serve, including disadvantaged communities.
  • The LCRI’s 10-year replacement deadline is unrealistic for small water systems.
  •  Small water systems will experience multiple implementation issues fulfilling the LCRI’s requirements.

For more information, please contact Nick Goldstein, Assistant Chief Counsel, at, or call (202) 772-6948.