May 4, 2020 Dr. Thomas Armitage Designated Federal Officer (DFO) EPA Science Advisory Board (1400R) U.S. Environmental Protection Agency 1200 Pennsylvania Avenue NW Washington, DC 20460 (
[email protected]) Re: SAB Review of the Proposed National Primary Drinking Water Regulation for Lead and Copper, 84 Fed.Reg. 61684 (November 13, 2019). Dear Dr. Armitage: On behalf of the Natural Resources Defense Council (NRDC), a national non-profit organization with over 3 million members and activists, we appreciate this opportunity to comment to the Science Advisory Board regarding the EPA Proposed National Primary Drinking Water Regulations: Lead and Copper Rule Revisions (LCRR), 84 Fed. Reg. 61684 (Nov. 13, 2019). NRDC scientists, lawyers, policy and other experts are dedicated to safeguarding human health and the environment for current and future generations. NRDC has been actively working on the Safe Drinking Water Act for more than 40 years and has been deeply engaged in seeking to strengthen protections against lead in drinking water for more than three decades. We commented extensively on the 1988 Lead and Copper Rule (LCR) proposal that was finalized in 1991 and participated in the litigation challenging that rule. NRDC also is working to improve public health protections from lead-contaminated tap water through litigation and administrative proceedings in several specific cities. These include actions on behalf of local residents and organizations and our members in Flint, Michigan, Newark, New Jersey, and Pittsburgh, Pennsylvania. Through this and other work, we have learned a great deal about the LCR and the scientific issues posed by its implementation. The EPA LCRR represents an important opportunity to substantially improve the current rule; we are pleased that the SAB is reviewing the agency’s proposal and appreciate the chance to provide our views to the Board.