Our organization is committed to achieving a lead-free drinking water system through evidence-based decision-making. To that end, we submitted the comments regarding the EPA’s proposed modifications to the Lead and Copper Rule.
Based on our team's experience guiding the lead service line replacement project in Flint and our expertise in data science, our comments can be summarized in the following four bullets. The full comment can be found here.
Strengthening reporting requirements to include additional information about service line materials that are known
Limiting the reliance on historical records before 1989
Allowing water systems more flexibility in managing their unknowns using statistics
Changing the assumptions in the economic analysis to be reflect actual cost of service line replacement.