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National Primary Drinking Water Regulations: Lead and Copper Rule Revisions
Activity
American Water Works Association filed 17 comments on this docket between Nov 14, 2019 and Apr 14, 2021. 95 other organizations filed here. The comment window closed 911d ago.
What American Water Works Association filed (17)
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The Florida Section of the American Water Works Association Water Utility Council (FSAWWAWUC) respectfully submits our comments in the attached document.
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These comments and recommendations are submitted to EPA from the Kentucky Water Utility Council of the KY/TN AWWA. Submitted by Greg Heitzman on behalf of Amy Kramer, Chair of the Kentucky Water Utility Council.
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The American Water Works Association NJ Section (AWWA-NJ) appreciates the opportunity to provide input to the Environmental Protection Agency's November 13, 2019, Federal Register notice, proposing revisions to the Lead and Copper Rule. Lead is a well-recognized public health concern. Success to-date to control environmental lead exposures are a tremendous success story, including the reduction of lead in drinking water accomplished under the Safe Drinking Water Act. As a nation we need to continue to make progress eliminating lead exposure.e AWWA-NJ has been actively involved with many organizations over the last few years demonstrating the commitment to reduction of health risks associated with lead and copper in drinking water. The following are some key initiatives: 1.Following the discovery of high lead in drinking water for schools in NJ, the AWWA-NJ Licensed Operator Committee (LOC) participated in a comprehensive training program for every school in NJ 2.The AWWA-NJ recently sponsored a forum on lead in drinking water at NJIT University in Newark NJ with experts from the USEPA, NJDEP, AWWA, Water Utilities, Advocacy Groups as well as the Newark's Mayor Ras Baraka. 3.The AWWA-NJ has been actively involved with the development of NJ legislation such as water infrastructure, LSL Inventories. LSL replacement, schools, daycares, hospitals and proposed regulations for the NJDEP. Shared responsibility is the central concept that underpins lead risk reduction across every media, but is particularly important with developing policies to manage lead in drinking water. Reduction of lead in drinking water requires a collaborative effort by the water system, customers, consumers, state regulators, federal agencies, financing authorities, plumbers, code officials, local government, and many others. AWWA-NJ agrees with EPA that in keeping with the Safe Drinking Water Act, water systems should take steps within their authority to reduce lead in water. AWWA-NJ hopes that these comments (see attached Lead and Copper Advisory Committee's White Paper) will help EPA finalize the rule expeditiously. In finalizing the rule, it is important that the Agency: 1.Clearly state in the rule that lead service line inventories are intended to guide proactive actions based on available information like that described in the proposed rule and additional data collected in the course of routine water system activities. Moreover, water systems, or portions therein, constructed following the Safe Drinking Water Act Lead Ban or other state or local policies with like effect, should be able to certify that lead service lines are not present rather than complete the inventory-related activities in the rule. 2.Water systems should be prepared to assist schools and childcare facilities in the communities they serve upon request. Lead exposure in K - 12 schools and childcare facilities is important and must be addressed by those facilities. AWWA-NJ supports action based on EPA's Memorandum of Understanding on Reducing Lead Levels in Drinking Water in Schools and Child Care Facilities with sector associations and its federal agency partners. The best strategy to address lead in schools and childcare facilities is through a holistic risk 3.reduction strategy as described in the Federal Action Plan to Reduce Childhood Lead Exposures and Associated Health Impacts which should be implemented through the Department of Education, Health and Human Services, and EPA in collaboration with relevant state agencies. 4.Corrosion control is a critical tool in managing lead in drinking water that must be implemented taking many more considerations than are reflected in the proposed rule into account. EPA must allow water systems to identify and manage corrosion control using an array of tools to support timely and cost-effective decision-making rather than the rigid framework proposed. Evaluation of corrosion control should begin with an assessment of whether the system is…
The Indiana Section of the American Water Works Association respectfully submits the comments in the attached document.
Comments submitted on behalf of the American Water Works Association are attached.
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The New York Section of the American Water Works Association respectfully submits the comments in the attached document.
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Attached is a request that EPA extend the comment period for this proposal. The requesting organizations are the American Water Works Association, National Association of Water Companies, National League of Cities, National Rural Water Association, and the U.S. Conference of Mayors. Contact information for each organization is included in the request.
Abstract
The objective to the long-term revisions to the Lead and Copper Rule is to improve public health protection while ensuring effective implementation.
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See everyone who commented →- American Water Works AssociationTHIS ORG17 filings · confidence 97%
- Environmental Defense Fundtrade assoc.7 filings · confidence 97%
- Association of State Drinking Water Administratorstrade assoc.5 filings · confidence 85%
- Environmental Council of the Statestrade assoc.4 filings · confidence 85%
- Natural Resources Defense Council (NRDC)trade assoc.4 filings · confidence 97%
- Association of Metropolitan Water Agenciestrade assoc.3 filings · confidence 97%
- Environmental Protection Network (EPN)trade assoc.3 filings · confidence 97%
- Joseph Cotruvo & Associates LLCunverified attribution2 filings · confidence 70%
- Louisville Water Companyunverified attribution2 filings · confidence 70%
- National Association of Clean Water Agencies (NACWA)trade assoc.2 filings · confidence 97%
- Southeast Florida Utilities Counciltrade assoc.2 filings · confidence 85%
- Southeast Michigan Council of Governmentstrade assoc.2 filings · confidence 85%
- University of Iowaunverified attribution2 filings · confidence 70%
- A.O. Smith Corpunverified attribution1 filing · confidence 70%
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