Lead and Copper Rule Revisions Public Listening Sessions
April 28, 2021
Overview: 
The U.S. Environmental Protection Agency's (EPA) first set of public listening sessions on the Lead and Copper Rule Revisions (LCRR) was held on April 28, 2021. This was the first of EPA's planned public engagements to obtain further input on the LCRR. Due to the COVID-19 pandemic, this set of public listening sessions was held virtually over the Zoom platform. Members of the public who had registered to speak were each given three minutes to provide their comments. These meetings were also broadcast to YouTube so that members of the public wishing to listen could watch the sessions in real time.
Each session was structured with one EPA facilitator and three EPA senior staff, referred to as listeners, who listened to commenters' statements. At the beginning of every session, the facilitator welcomed and thanked commenters for joining and invited them to view two videos prepared by EPA, a welcome video from EPA Administrator Michael S. Reagan as well as an introduction video on the LCRR and the public engagements titled "LCR 101", at https://www.epa.gov/ground-water-and-drinking-water/lead-and-copper-rule-revisions-virtual-engagements. 
The EPA listeners introduced themselves and thanked commenters for taking the time to participate in these sessions and for providing statements about the impacts of lead in drinking water and the LCRR. The facilitator then reviewed the rules, designed to ensure an orderly and productive listening session, and invited commenters to make their statements. 
At the end of every session, the facilitator informed commenters and members of the public viewing the broadcast of the opportunity to submit written comments on the LCRR at https://www.regulations.gov using the docket number EPA-HQ-OW-2021-0255.
The sessions held on April 28[th] are described below and can be viewed as an .mp4 file posted to the docket, EPA-HQ-OW-2021-0255 at https://www.regulations.gov. 

Session 1: 10am-12pm EDT
The EPA facilitator for this session was Ryan Albert. The EPA listeners were Benita Best-Wong, Jennifer McLain, and Yu-Ting Guilaran. During this session, EPA heard comments from 11 members of the public that identified themselves as representing national associations, local governments, private citizens, and industry. 
Comment Themes: 
Health Concerns
Commenters were concerned about the impacts of lead on the health of young children in addition to those who are over six years old. It was mentioned that end users are not always aware of drinking water issues due to a lack of visibility of contaminants in water. Impacts are often felt more heavily on low-income communities and communities of color. 
Lead Service Line Replacement
Commenters in this session were advocating for a thorough lead service line replacement program that is consistent with President Biden's proposal to remove all lead service lines. Some commenters implored EPA to not forget about lead service lines owned by private citizens in their program. Commenters encouraged EPA to be aggressive with the timeline and goals of the lead service line replacement program.
Sampling in Schools and Child Care Facilities
Commenters supported enhancing protection for schools and child care facilities but wanted to ensure the efficiency and viability of the program. One commenter pointed out that infrequent sampling cycles may give child care centers, schools, and the utilities that supply them a false sense of security that lead is not present in drinking water. Adding in a requirement for filters would further protect these highly vulnerable end-users.

Session 2: 12:30pm-2:30pm EDT
The EPA facilitator for this session was Karen Wirth. The EPA listeners were Dimple Chaudhary, Eric Burneson, and Anita Thompkins. During this session, EPA heard comments from 13 members of the public that identified themselves as representing national associations and organizations, and private citizens. 
Comment Themes: 
General Comments
Commenters stated that they believe there is a significant misrepresentation of lead levels in water due to the small number of samples required under the law. One commenter indicated that they felt it was appropriate for EPA to withdraw the LCRR to make it more effective and protective of public health. Another commenter stated that the 1991 Lead and Copper Rule has not been fully implemented and requested that EPA address factors that may impede implementation.
Health Concerns
Multiple commenters pointed out that there is no safe level of lead consumption according to most national organizations and as such, a 15 ppb Action Level is far too high. Multiple commenters advocated for EPA to implement a revised action level of 5 ppb. 
Lead Service Line Replacement
As with the previous session, commenters indicated their support for President Biden's call to replace 100% of the lead service lines in the U.S. and EPA should push to have full lead service line replacement within 10 years. One commenter added that while working towards that goal, EPA should prioritize service line replacement for people that are most vulnerable and at risk for lead poisoning. Commenters identified a need for a publicly available map identifying the presence or absence of lead service lines.
Sampling in Schools and Child Care Facilities
Some commenters spoke to the difficulties in sampling at child care facilities and schools, particularly during the COVID-19 pandemic and moving forward. One commenter believed the responsibility of testing should fall on the school or child care facility and not on the water system. Others indicated that more testing at child care facilities and schools would be appropriate to give those facilities a better picture of their lead risks -- without a proper understanding of risks and exposure, facilities could have a false sense of security. 

Session 3: 5:30-7:30pm EDT
The EPA facilitator for this session was Andrea Barbery. The EPA listeners were Joe Tiago, Casey Katims, and Eric Burneson. During this session, EPA heard comments from 5 members of the public that identified themselves as representing national associations and organizations, and private citizens. 
Comment Themes: 
General Rule
Multiple commenters indicated that they believed the revised rule, as published in the Federal Register on January 15, 2021, should not be promulgated. Commenters believed that the action level was too high and not protective of public health. One commenter pointed out that lead contamination incidents could still occur under the revised rule.
Lead Service Line Replacement
Multiple commenters indicated that the lead service line replacement timeline is too slow and that low-income communities of color are being disproportionately impacted due to their inability to afford replacing their portion of the lead service line. They also indicated that EPA should prioritize the removal of lead service lines from communities defined as environmental justice communities. 
Health Effects
Multiple commenters reiterated that research shows there is no safe level of lead and because of this, the rule is not protecting public health. One commenter proposed higher frequencies of blood level testing in children to help identify communities that have higher exposures to lead. 
Sampling in Schools and Child Care Facilities 
One commenter argued for higher amounts of sampling in schools and that the remediation requirements for schools should be clarified further in the revised rule. Another commenter emphasized that if one school in the community is found to have low lead levels that the community may have a false sense of security that other schools have similar lead levels, when that may not be true. 


