EPA unveiled its draft Strategy to Reduce Lead Exposures and Disparities in U.S. Communities on October 28. The draft Strategy aligns with the Biden Administration’s commitment to address ongoing exposures to lead, and it builds upon the progress already made on reducing lead with particular attention paid to overburdened communities and environmental justice concerns.

The goals of the draft Strategy include reducing community exposures to lead sources; identifying communities with high lead exposures and improving those communities’ health outcomes; communicating more effectively with stakeholders; and supporting critical research to inform efforts to reduce lead exposures and related health risks.

EPA’s draft strategy will attempt to approach these goals by identifying communities where lead levels are known or are reasonably expected to be highest, and then find and mitigate the sources and exposure pathways. In addition, EPA will be developing and implementing national standards, policy, and guidance, as well as ramping up enforcement of regulations and statutory requirements. EPA will be specifically looking at reducing exposure via lead-based paint, drinking water and soils.

Although lead is primarily a drinking water issue that impacts public water systems (PWSs) under the Safe Drinking Water Act, NACWA has previously weighed in with EPA on its efforts to revise and update its Lead and Copper Rule (LCR). NACWA’s comments have urged EPA to consider the potential downstream impacts to municipal clean water utilities regulated under the Clean Water Act.

NACWA is also concerned EPA will take a “one-size-fits-all” approach to determining corrosion control treatment, rather than allow states and PWSs the flexibility to select the best corrosion control protection method for their site-specific water quality needs and infrastructure characteristics.

The draft lead strategy refers to a national standard, but it does not go into any detail of what this may mean for PWSs or whether orthophosphate, a common corrosion control treatment technique, will be the gold standard. While EPA is accepting comments for 90 days on its draft Strategy, it is also reviewing the Trump Administration’s LCR rulemaking to ensure it aligns with the current Administration’s goals and objectives on addressing lead in drinking water.

NACWA is considering submitting comments to EPA on its draft Strategy. If members have comments or concerns, please contact Emily Remmel, NACWA’s Director of Regulatory Affairs.