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CAP Comments on the EPA’s Proposed Lead and Copper Rule Improvements

The Center for American Progress submitted a comment letter to the U.S. Environmental Protection Agency in response to the agency’s proposed improvements to the Lead and Copper Rule.


Jill Rosenthal, Hailey Gibbs, Allie Schneider, and Mariam Rashid (February 5, 2024)



On February 5, 2024, the Center for American Progress submitted a comment letter to the U.S. Environmental Protection Agency (EPA) in response to the agency’s proposed improvements to the Lead and Copper Rule, which includes provisions to replace all lead pipes in the United States within 10 years, lower the lead action level, and improve tap sampling and communication with communities about lead exposure risks. CAP’s letter supports the EPA’s efforts to remove and fully replace all lead service lines (LSLs) within the accelerated time frame. This goal is critical to protecting an estimated 22 million people across the nation who are currently exposed to lead in drinking water—disproportionately people of color and people from low-income households. CAP emphasizes that there is no safe level of lead and that young children in particular are at a high risk of negative health and developmental consequences due to any level of lead exposure.

CAP urges the EPA to consider several opportunities to strengthen the rule and further protect vulnerable communities from lead health risks. These recommendations include: 1) clarifying and removing the financial responsibility for property owners to pay for the cost of replacing a portion of an LSL that falls on private property; 2) reducing allowable lead levels from 10 parts per billion to between zero and five parts per billion; 3) enhancing requirements and communication about community health risks to improve outreach and engagement, particularly among vulnerable communities; and 4) supporting water systems—particularly those that serve smaller rural communities and communities of color that are most exposed to LSLs—in accessing existing funding to cover LSL replacement projects.


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