Fw: Earthjustice draft comments on EPA's proposed revisions to the Lead and Copper Rule--TIME SENSITIVE REQUEST--SIGN ONS NEEDED BY NOON EST ON WED 2/12
Sara Perl Egendorf
Sent: Tuesday, February 11, 2020 5:25 PM
To: leadpb-r...@googlegroups.com <leadpb-r...@googlegroups.com>
Cc: sno...@earthjustice.org <sno...@earthjustice.org>; cwoo...@earthjustice.org <cwoo...@earthjustice.org>
Subject: RE: Earthjustice draft comments on EPA's proposed revisions to the Lead and Copper Rule--TIME SENSITIVE REQUEST--SIGN ONS NEEDED BY NOON EST ON WED 2/12
*Apologies for cross-posting*
Thank you to all of you who provided input on and/or signed onto Earthjustice’s draft comments on EPA’s proposed revisions to the Lead and Copper Rule. Attached is a new-and-improved revised draft. If you haven’t signed on already and would like to, please do so here: LCR comments sign up form no later than noon EST tomorrow!
Since the comments are lengthy, we wanted to highlight for you some of the bigger changes that have been made since the first draft was circulated:
- We have added a stand-alone environmental justice section, starting on page 35.
- We have fleshed out the section on public education, starting on page 27.
- We have fleshed out the section on why EPA should institute an MCL, starting on page 3.
- We have revised/added to the monitoring for lead in schools and child care facilities, starting on page 29.
(Please note that we are still formatting, filling in cites, etc).
Here is a link to EPA's proposed rule. Thank you for joining us in trying to get EPA to do all it can to reduce exposure to lead in drinking water! And please share with your partners.
From: Jonathan J. Smith
Sent: Sunday, February 9, 2020 2:02 PM
To: leadpb-r...@googlegroups.com
Cc: Suzanne Novak <sno...@earthjustice.org>; Christian Wooddell <cwoo...@earthjustice.org>
Subject: Earthjustice draft comments on EPA's proposed revisions to the Lead and Copper Rule--TIME SENSITIVE REQUEST--SIGN ONS NEEDED BY NOON EST ON WED 2/12
*Apologies for cross posting.*
Dear Lead Roundtable,
Sharing below and attached Comments drafted by Earthjustice on EPA’s proposed revisions to Lead and Copper Rule. We welcome your feedback by Monday and sign on by Wednesday.
Begin forwarded message:
As you may know, EPA is proposing its most comprehensive amendment to the Lead and Copper Rule (LCR) of the Safe Drinking Water Act in three decades Here is a link to EPA's proposed rule. We have attached draft comments to the proposal and seek your input on the comments, and possibly your agreement to sign on to them. The comments must be filed on Wednesday, February 12. With apologies for the tight turnaround time, we request that you try to provide input to us on the comments no later than 4 pm EST on Monday, February 10 so that we may incorporate input and turn around another version to you all on Tuesday, February 11. (Please note that we are still working on the comments, so there are some sections that are not completely written, and we will still be working to tighten up the language, fix typos and cites, etc. throughout the document) We will need all sign ons no later than noon EST on Wednesday, February 12. If you would like to sign on to these comments, please email the following to Christian Wooddell, cc’ed here, no later than noon EST on Wednesday, February 12: Your name and, if applicable, your title and organization.
The current LCR is designed to control lead and copper in drinking water, but is significantly flawed. EPA’s proposed rule makes some improvements to the LCR, but does not go far enough to protect public health. Unfortunately, the proposal also takes some steps backwards to be less health protective, steps that in some instances violate EPA’s duties under the law. The draft comments highlight these areas and arguments, and suggest ways that EPA could and should improve its proposal. We are particularly interested in hearing your input on ways EPA should improve its proposal. As you will see, some areas for which we are particularly seeking input are highlighted in yellow, largely in the school testing and public education sections at the end.
Please feel free to share with your partners. We look forward to hearing from you!
Regards,
Suzanne, Michelle and Mekela
Suzanne Novak
Staff Attorney
Earthjustice Northeast Office
48 Wall Street, 15th Floor
New York, NY 10005
T: 212.823.4981
Pronouns: she/her/hers
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