Document KVKLmDE5y5LjX34NopDVBN0
Congress of ttfo United States
Sfiusiffiigfott, 3 20515
March 8, 2018 The Honorable Scott Pruitt Administrator U.S. Environmental Protection Agency William Jefferson Clinton Building 1200 Pennsylvania Avenue NW Washington, DC 20460
Dear Administrator Pruitt;
We welcome the Environmental Protection Agency (EPA)'s rvaluation o f the current Lead and
Copper Rule (LCR) that is more than 25 years old. With more than 18 million Americans being
served by water systems in violation o f the current LCR and more than 5,300 communities with
unsafe service
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all
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circumvented.
Childhood lead exposure can have devastating long-term consequences. The current "acceptable" level of lead exposure is two micrograms o f lead per deciliter, and anything over five micrograms is considered "unacceptable," but even small amounts of lead can cause serious health problems. The impact o f lead poisoning ranges from reductions in cognitive function, developmental delays, behavior modification, learning disabilities, seizures, comas, and even death. Furthermore, as we've seen across the nation, lead poisoning continues to disproportionately impact low-income areas and communities of color, contributing to racial, health, and economic disparities across the country.
Hundreds o f thousands of children aged one to five years old in the U.S. have blood lead levels above five micrograms per deciliter, 150 percent above acceptable levels. Water consumption is estimated to contribute 10-20 percent o f a child's total lead intake. For formula-fed infants, it is estimated to be 40- 60 percent o f a child's lead exposure1. The effects of lead poisoning on children are especially harmful, and the Centers for Disease Control and Prevention have determined that there is no "safe" level o f lead for a child. The annual costs of lead poisoning are over $50 billion, and these costs are especially regrettable since lead poisoning is entirely preventable.
Across the country, local health departments are grappling with lead exposure in young children, but lack adequate resources to address the issue. In the last year, there have been reports from New York City to the Hawaiian Islands and from Waco to Chicago about local communities dealing with elevated lead levels in children. Nationwide, more than 5,300 water systems violate
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the existing LCR, with several major cities including Philadelphia, Chicago, Milwaukee, Baltimore and Boston reporting water systems with lead concentrations well above the federal limit. Appallingly, testing o f school water systems has led to many water fountains being deemed "off limits" and some 30 schools in Newark, New Jersey, have had to turn off their taps entirely.
The citizens o f Flint,
crisis, and according
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of in
what is actually violation o f the
a nation-wide current rule. Many
lead violations across the country have long-been covered up by intentional use of monitoring
techniques that avoid detecting lead problems. The EPA has allowed these techniques to
continue without consequence. EPA is not alone in culpability, state and local agencies that
report to the EPA also have blame for failure to properly inspect water systems or to properly
document violations, violations; they have
but put
the EPA millions
omfucshtilrderaelnizeatthriastke. aWche
time they have turned a blind must implement strict testing
eye
to
lead
procedures and discourage creative testing strategies that allow failing systems to persist.
Additionally, any changes to the rule must be accompanied by stronger EPA enforcement to ensure compliance with these critical federal protections. Communities will not realize the full benefit o f changes to the LCR if they are not being properly implemented by local and state authorities. The EPA cannot know about how these changes are being implemented without a strong and effective monitoring and enforcement regime.
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to many of the Accountability
lOeaffdicaen(dGcAopOp)e2r,
violations illustrates
across the nation. the extent o f the
water infrastructure problem. In the older industrial cities, deemed "legacy cities" by GAO, there
are declining populations, as well as, high poverty crumbling water infrastructure that EPA estimates
and will
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have two
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called for in the President's Budget Request for both FY2018 and FY2019, will only exacerbate
tahdevperrsoebllyemaf.feTchtemseonbiutodrgientgraeqnduessttasfnfiontgoanslywieglnl.ore critical infrastructure needs, but will likely
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defined by the zip outdated rule to
ensure our children grow up healthy and safe.
linked States Government Accountability Office. Water Iitfrasintcmre:Information on Selected Midsfce cmd Large Cities wish edittmg Populations. 2016,
Sierra Club v. EPA 18cv3472 NDCA
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ED 002061 00096264-00002