February 12, 2020
The Honorable Andrew Wheeler Administrator Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460
Re: Comments regarding Docket ID No. EPA-HQ-OW-2017-0300
Dear Administrator Wheeler,
As leaders of the Great Lakes-St. Lawrence Legislative Caucus (GLLC), we are writing to submit the GLLC’s comments on the U.S. Environmental Protection Agency’s Notice of Proposed Rulemaking, proposing revisions to the existing Lead and Copper Rule (LCR), published in the Federal Register on November 13, 2019 (Vol. 84, No. 219, pp. 61684-61774). The GLLC is a nonpartisan, binational organization of state and provincial legislators who advocate for clean water policies and programs in the 10 jurisdictions that share the Great Lakes and St. Lawrence River. One of the Caucus’s highest policy priorities is assuring the availability of safe, clean, affordable drinking water. In 2018, we organized a Task Force on Lead to guide our regional collaboration on policies intended to reduce the population’s exposure to lead in drinking water, with special emphasis on protecting children. The Task Force developed an action plan and model policy for GLLC members to implement. Our comments on the LCR draw from the model policy and the many informational resources that the task force has obtained from EPA, state and provincial legislative offices and departments of health, and other individuals and organizations that work to eliminate lead from our drinking water.
Our comments focus on five aspects of the proposed LCR revisions:
1. Funding
Protecting public health is our primary concern. Nevertheless, we put funding at the top of our list of issues because, as legislators, we are keenly aware that all the actions EPA proposes – as well as the actions we are recommending – come at a cost. Governments at all levels, community water systems, and facilities like schools and child care facilities are
The Council of State Governments Midwestern Office 701 E 22 nd Street, Suite 100 Lombard, IL 60148 630.925.1922 www.csgmidwest.org
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