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On January 15, 2021, EPA promulgated the final Lead and Copper Rule Revisions (LCRR), the most comprehensive update so far to the original 1991 Lead and Copper Rule. Following executive review and additional stakeholder input, the LCRR went into effect on December 16, 2021. EPA also noted several areas for additional improvements to the LCRR and committed to promulgating the Lead and Copper Rule Improvements (LCRI) rule by late 2024. The LCRR has an early implementation requirement for public water systems to complete initial lead service line inventories by October 16, 2024. The division is conducting a stakeholder process for the Water Quality Control Commission (Commission) to adopt the LCRR, so that it is effective in Colorado by December 16, 2023 and provides the department enforcement authority, instead of the EPA. This rulemaking process could prove challenging depending on the changes promulgated in the LCRI and when they become effective.
The LCRR emphasizes lead service line identification and replacement requirements, creates a new lead “trigger level” below the current “action level,” and requires lead sampling at schools and child care facilities. The LCRR adds considerable complexity for both states and water providers. However, some public health experts and community activists believe the LCRR falls short in achieving removal of lead service lines and reducing lead exposure.
Despite the uncertainty, CDPHE is moving forward to adopt LCRR. LCRR will be adopted and integrated into our existing Colorado Primary Drinking Water Regulations (Regulation 11). The division sees great value and opportunity to gain shared understanding by discussing the requirements during the stakeholder engagement and subsequent rulemaking process. Given the complexity of this rule, these interactions would be invaluable for the division and water suppliers. This will also allow the division to better understand the additional resources needed for LCRR implementation. The division will continue to monitor information from EPA regarding LCRI and its impact on moving forward with LCRR adoption.
The LCRR stakeholder process launched in July 2022 and is moving forward toward an August 2023 Rulemaking Hearing before the Commission to adopt LCRR. Visit our LCRR web page to get engaged or simply see a great deal of resources to help you and your water system get ready for LCRR.
➽ Bryan Pilson, Haley Orahood, Nicole Graziano, and Ron Falco, P.E. Safe Drinking Water Program
