February 11, 2020 – Today, the Clinic, Environmental Defense Fund (EDF), and Dr. Karen Baehler of American University submitted comments focused on the health equity, environmental justice, and civil rights aspects of the EPA’s proposed revisions to its Lead and Copper Rule (LCR).
The Clinic’s/EDF’s analysis of the proposed revisions, as well as Dr. Baehler’s study of lead service line replacements, indicate that the revisions are likely to make environmental justice and health equity issues worse, contrary to EPA’s assessment that the revisions “are not expected to have disproportionately high and adverse human health or environmental effects on minority populations and low-income populations.”
The comments make the following recommendations:
- EPA should modify its proposed new lead service line planning requirements to require water systems to prevent disproportionate impacts to low-income and minority residents;
- EPA should require community water systems to demonstrate that their implementation of the LCR will not result in significant disproportionate impacts on low-income and minority residents; and
- EPA should require that community water systems track performance on health equity and environmental justice impacts.
Clinic student Laurel Petrulionis (JD’21) worked on the comments under the supervision of Deputy Director Shaun Goho.
Click below to view the comments:
Comments regarding health equity, environmental justice, and civil rights aspects of proposed revisions to its Lead and Copper Rule in the National Primary Drinking Water Regulations, Docket No. EPA–HQ–OW-2017-0300