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What Does the Recently Proposed LCRI Mean for Water Utilities?
A revision of the LCRI was recently submitted to the Office of Management and Budget for Approval. What does this mean for water systems? We chatted with 120Water’s Director of Water Quality Compliance, Jonathan Cuppett, to find out!
Posted on October 4, 2023
Read about it here:
Isaac:
Everyone, this is Isaac with 120Water. I just asked Jonathan Cupett to join me just to explain what this means. We saw this news that the proposed lead and copper rule improvements have been submitted to the office of management and budget for approval. And so Jonathan, what does that mean for water systems who are working on their inventories?
Jonathan:
Yeah. So we’ve been getting a lot of questions about this lately. And so let me just summarize the current situation. And let me start by saying, you know, this is not a surprise. And those recent developments have always been expected. So when the lead and copper rule revisions or the LCRR were finalized in 2021, the EPA announced that a new role making called the Lead and Copper Rule Improvements or the LCRI would be finalized prior to the October 2024 compliance deadline for the LCRR.
So, essentially, what that means is the LCRI will replace the LCRR.
So last month, As Isaac mentioned, the LCRI was submitted to the federal office of management and budget for approval.
Now, this is a standard process that regulations go through prior to their release.
So EPA has said that they intend for the LCRI proposal to be released to the public in October of this year. So let’s just say by Halloween.
Now keep in mind that once the LCRI proposal is released, it is just a proposal, and the public will still have the, you know, the opportunity to comment on the proposal before it is finalized.
So I think a lot of water systems are trying to understand how they may impact them. So we know that the LCRR has a variety of requirements, including the service line inventory, the lead service line replacement plan, changes to sampling requirements, sampling of schools and child cares, changes to corrosion control, the new lead trigger level, amongst a variety of other elements. And so really the big question is, how is this new role of the LCRI, going to impact the requirements and deadlines for all of these elements that I just described.
The truth is we really do not know and we’re going to need to wait until the LCRI is released until we so we can get a better understanding about those specific issues.
But we do know one thing. The service line inventory requirements in the October 16th, 2024 deadline for the inventory is not going to change.
But we still do not know how the new rule is going to impact those other LCRR requirements.
We also do not know how this new role is going to impact the compliance deadline for these other LCRR requirements.
So, for example, will some of the elements that I discussed be required prior to 2027, which really would represent the the standard, the standard 3 years from the time of regulation is finalized, until systems do need to comply.
We just don’t know right now. So to really summarize this issue, you know, nothing has changed. We still have uncertainty with how the LCRI is going to impact the LCRR, but we do expect to have some clarity on this issue once this LCRI proposal is released in the near future. And so I think moving forward, if I were a water system, there’s really three things that I would recommend.
Number one, continue to focus on the service line inventory.
We know the requirements and deadlines for that are not gonna change.
Number two, I would continue to explore funding options in your state. So the bipartisan infrastructure law allocated around fifteen billion dollars through the drinking water SRF program. And that fifteen billion dollars is divided among the states. And those funds can be used for inventories including verification for your inventory.
Those funds can also be used for replacing lead service lines. And finally, I just would be on the lookout for any learning opportunities provided through the water industry later this year once the LCRI proposal is released.
Isaac:
That’s great. So, yeah, so the main point here, especially for systems that are working on their inventory, you’re doing the right thing. If you haven’t started working on your inventory, getting started now because we’re one year away from that requirement of that submission. And so starting now is the right time to start.
Thank you so much, Jonathan.
