Supporting Statement A

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U.S. Environmental Protection Agency
Information Collection Request

Title: Information Collection Request for the Final Lead and Copper Rule Improvements (LCRI)
OMB Control Number: 2040-NEW
EPA ICR Number: 2788.02
Abstract: The National Primary Drinking Water Regulations (NPDWRs) for Lead and Copper (the Lead and Copper Rule or LCR), was promulgated by the U.S. Environmental Protection Agency (EPA) in 1991, is a regulation promulgated under the Safe Drinking Water Act (SDWA). The LCR’s goal is to reduce the levels of lead and copper in drinking water. The final Lead and Copper Rule Improvements (LCRI) builds upon the LCR and subsequent revisions including the most recent 2021 Lead and Copper Rule Revisions (LCRR). The final LCRI requires community and non-transient non-community water systems1 to replace lead service lines (LSLs) and galvanized requiring replacement (GRR) service lines (galvanized lines currently or previously downstream of an LSL) and, under specified conditions, install source water treatment, install and/or reoptimize corrosion control treatment (CCT), conduct public education, or distribute and maintain point-of-use (POU) treatment. The final LCRI also expands public education requirements for lead and requires greater public access to information on lead.
The final LCRI is designed to identify and reduce lead exposure at systems with elevated lead concentrations in their drinking water by establishing a new lead action level (AL) of 0.010 miligrams per liter (mg/L). Note, the maximum contaminant level goals (MCLGs) for both lead and copper have not been modified by the final LCRI. See the Economic Analysis for the Final Lead and Copper Rule Improvements (available in the docket at EPA-HQ-OW-2022-0801 at www.regulations.gov) for detailed information on the specific regulatory requirements of the rule.
Water systems include Federal, State, Tribal, and local governmental entities as well as private entities. States (and Tribes) that have been granted primary enforcement authority (i.e., primacy) for the LCRI are responsible for overseeing rule implementation by systems within their jurisdiction. In instances where a State or Tribe does not have primacy, the EPA Region is the primacy agency.2 Systems demonstrate compliance through reporting information to the State. States utilize the data to determine compliance and review service line replacement plans that target the removal of lead service lines that, where present, are the greatest source of lead exposure in drinking water. States also are required to report a subset of the data to the EPA, which utilizes this information to protect public health by ensuring compliance with the LCRI, measuring progress toward meeting the LCRI’s goals and evaluating the appropriateness of state implementation activities. The information reported by States to the EPA can be found in the Safe Drinking Water Information System (SDWIS).
The final LCRI requires water systems to replace lead service lines, sets the lead action level to 0.010 milligrams per liter (mg/L), and strengthens tap sampling procedures, among other changes that improve public health protection and simplify the rule relative to the 2021 LCRR. This final rule provides improvements in the additional following areas: CCT, public education and consumer awareness, requirements for small systems, and sampling in schools and child care facilities. The EPA's final rule includes actions  to protect public health including in communities disproportionately impacted by lead exposures, including through lead and GRR service line replacement and public education, among other areas of the final rule. This final rule also increases transparency of lead and copper sampling through requiring that individual sample results be provided to consumers regardless of the level found. 
This ICR supporting statement estimates the incremental burden impacts of revisions to the LCR and 2021 LCRR in terms of the burden and costs for the first three years after the rule is published (estimated as 2024 to 2027). The LCRI implementation period overlaps with the LCRR renewal and supplemental ICR and supersedes or removes some LCRR requirements. As a result, the initial burden and cost estimates for the LCRI double-count burden estimates in the requested Information Collection Request for the Lead and Copper Rule Revisions (OMB Control Number 2040-0297; EPA Tracking Number 2606.03). The EPA provides an estimate of the double counting and subtracts that amount from the final net estimates.
During the three-year period covered by this ICR, public water systems will conduct one-time startup activities that include the following:
    • reading and understanding the rule;
    • assigning personnel and resources for rule implementation;
    • attending training and receiving technical assistance from the State;
    • updating and submitting to the State a baseline service line inventory that includes lead connector information; 
    • preparing and submitting to the State a service line replacement plan, including information on participation in a deferred replacement plan, if eligible, and identifying funding options for full service line replacements;
    • developing and submitting to the State for approval public education materials for customers with lead, GRR, and unknown service lines that must be delivered annually; and
    • updating and submitting to the State a tap sampling plan.

	During this time period, public water systems will also conduct on-going activities that include the following:
    • collect service line information during normal operations and conduct targeted field operations to update the material status of unknown service lines; and
    • distribute public education materials to customers with lead, GRR, and unknown service lines annually.
Also, during the three-year period cover by this ICR, States will incur burden associated with one-time startup activities that include the following:
    • adopting the rule into State regulations and developing an implementation program;
    • modifying their data system; 
    • providing State staff with training for implementation;
    • providing system staff with training and technical assistance;
    • reviewing baseline inventories with lead connector information;
    • reviewing service line replacement plans; including reviewing information on the deferred deadline and associated replacement rate in the SLR plan and determine fastest feasible rate; 
    • providing templates and reviewing public education materials for customers with LSLs, GRR service lines, and unknown service lines; and
    • reviewing the updated tap sampling plans.

Activities outside the initial three-year period are not included in this ICR supporting statement’s burden estimates. Exhibit 1-1 in Chapter 1, Section 1.1 of the EPA’s Economic Analysis of the final LCRI (available in the docket at EPA-HQ-OW-2022-0801 at www.regulations.gov) summarizes the additional activities required by the final LCRI that will take place after the initial three years covered by this ICR.
For the first three years after the rule is published, the average burden associated with this ICR is estimated to be 3,987,886 burden hours per year.3 The corresponding costs are estimated to be $348,472,952 per year. The EPA estimates the average respondent burden for PWSs to be 3,653,131 hours per year. Respondent costs for PWSs are estimated to be $328,392,257 per year. The agency estimates that the average burden for States is 334,755 hours per year. The corresponding respondent costs for States are estimated to be an average of $20,080,695 per year. The rule implementation activities and the development of public education materials for PWSs are assumed to occur in the first year, the service line replacement plan and tap sampling plan are assumed to occur in the third year, and public education distribution are spread over the first three years. Updating this service line inventory including the addition of connectors is distributed over the first three years, recognizing systems must submit this updated inventory (the base line inventory) upon the LCRI compliance date. The State adoption, and training are distributed over the first three years while the State development of the public education template and review of the public education material is assumed to occur in the first year. The State review of the service line replacement plan, the tap sampling plan, and baseline inventory are assumed to occur in the third year. There is no agency burden or cost except where the agency acts as the primacy agency. However, burden and costs for cases where the agency acts as the primacy agency are accounted for under the State burden estimates.
The total number of respondents for this ICR is 67,003. Fifty-six of these respondents are States, and the remaining 66,947 respondents are water systems. As the LCRI implementation period overlaps with the submitted LCRR renewal ICR, the initial burden and cost estimates for the LCRI double-count burden estimates in the requested LCRR ICR. The EPA removes that double-counting in the final net estimates. The net average burden associated with this ICR is estimated to be 305,574 burden hours per year. The corresponding total respondent costs are estimated to be $43,849,560 per year. The EPA estimates the respondent burden for PWSs to be 79,849 hours per year. Respondent costs for PWSs are estimated to be $61,216,127 per year. The agency estimates that the respondent burden for States is -225,725 hours per year. The corresponding respondent costs for States are estimated to be $17,366,566 per year. The average annual net burden per response is -0.11 hours. The average annual net cost per response is $6.65.
Supporting Statement A
    1. NEED AND AUTHORITY FOR THE COLLECTION
Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.
The EPA needs comprehensive and current information on lead and copper occurrence and associated enforcement activities to implement its program oversight and enforcement responsibilities mandated by SDWA, and they are critical to the EPA’s administration of targeting funding and financial assistance programs. The EPA identified rule changes in the final LCRI that clarify the LCRR requirements and ensure and improve protection of public health through reduction in lead exposure. The EPA will use the information collected to support the responsibilities outlined in SDWA. The EPA strengthened rule implementation in the areas of monitoring, customer awareness, CCT, and service line replacement. The final LCRI does not alter the current MCLGs or treatment technique approach to controlling lead and copper in drinking water.
The authority for this collection is derived from different parts of SDWA, including the definition for a “primary drinking water regulation” under Section 1401(1)(D) of SDWA, which requires that a “primary drinking water regulation means a regulation” that “contains criteria and procedures to assure a supply of drinking water which dependably complies with such maximum contaminant levels [or treatment techniques promulgated in lieu of a maximum contaminant level]; including accepted methods for quality control and testing procedures to [e]nsure compliance with such levels and to [e]nsure proper operation and maintenance of the system...” Furthermore, Section 1445(a)(1)(A) of SDWA requires that “[e]very person who is subject to any requirement of this subchapter or who is a grantee, shall establish and maintain such records, make such reports, conduct such monitoring, and provide such information as the Administrator may reasonably require by regulation to assist the Administrator in establishing regulations under this subchapter, in determining whether such person has acted or is acting in compliance with this subchapter, [and] in administering any program of financial assistance under this subchapter...” In addition, Section 1413(a)(3) of SDWA requires primacy agencies to “keep such records and make such reports...as the Administrator may require by regulation.” The sections from the SDWA 1996 Amendments, discussed above, are included as Appendix A to this document.
    2. PRACTICAL UTILITY/USERS OF THE DATA
Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.
Primary users of the data collected under this ICR are the EPA, water system managers, consumers, and primacy agencies (i.e., State, territorial, and Tribal regulators and, in some instances, the EPA Regional Administrators). This section contains more information about how the lead and copper data generated by the final LCRI regulatory requirements will be used. The final requirements discussed below pertain to the initial three-year period following promulgation of the LCRI covered by this ICR. For a detailed list of all final LCRI regulatory changes see Chapter 1 of the EPA’s Economic Analysis for the Final Lead and Copper Rule Improvements (available in the docket at EPA-HQ-OW-2022-0801 at www.regulations.gov).
The final LCRI assumes that systems will have completed an initial service line inventory to comply with the requirements of the LCRR. This initial assessment is based on a comprehensive service line materials inventory that identifies LSLs, GRR service lines (galvanized pipes that are currently or have been downstream of an LSL), lead status unknown service lines (service line material is not known to be lead, GRR, or a non-lead service line), and non-lead service lines. The final LCRI includes additional requirements to review records for information on connector materials and include lead connectors in the baseline inventory by the compliance date of the final LCRI.  This updated inventory must include a street address with each service line and connector. As with the 2021 LCRR, this inventory must be made publicly accessible, and available online for systems serving greater than 50,000 people. The final LCRI requires all service line inventories to be updated annually. The inventory will be used to:
    • inform system specific needs and planning associated with service line replacement;
    • provide information that will be used in the selection of lead and copper tap sampling sites;
    • improve targeting of public education materials to high risk customers;
    • evaluate the quality of water delivered to customers and effectiveness of CCT; and
    • assess compliance and determine when it is necessary to alert the public of possible health risks. 
The final LCRI also includes requirements for systems to update the educational materials designed to annually inform customers at locations with LSL, GRR, and unknown service lines of the potential health risks from drinking water lead exposure and steps they can take to mitigate their risks including participating in the system’s service line replacement program.
The final LCRI requires mandatory full service line replacement (both lead and GRR service lines) regardless of a system’s 90th percentile lead tap concentration. In order to implement service line replacement, the final LCRI requires all systems with at least one lead, GRR, or unknown service line to develop the service line replacement plan (as required in the 2021 LCRR), but also develop a strategy to inform customers and consumers about the replacement plan and program and identify any legal requirements or water tariff agreement provisions that govern the system’s ability to gain access to conduct full service line replacement. This service line replacement plan must be made publicly accessible; and available online for systems serving greater than 50,000 people. This plan would: provide information to affected customers on future mitigation efforts; help to identify potential impediments to achieving compliance with rule requirements and identify a funding strategy.
Primary users of the data collected under this ICR are water systems and their customers, primacy agencies, and the EPA. The information collected by the EPA is available to the public, via EPA’s website (https://www3.epa.gov/enviro/facts/sdwis/search.html) or by requesting the data under the Freedom of Information Act (FOIA; 40 CFR, Chapter 1, Part 2). Other organizations and individuals that may utilize the data include, but are not limited to, the following:
    • Individual consumers, realtors, potential homebuyers, homeowners, households, and other members of the public;
    • News organizations;
    • Staff from other EPA programs (such as Superfund, the Resource Conservation and Recovery Act, and the Office of Enforcement and Compliance Assurance);
    • The Federal Emergency Management Administration;
    • Centers for Disease Control and Prevention;
    • U.S. Department of Health and Human Services;
    • Military bases;
    • Farmers Home Administration;
    • U.S. Department of Interior;
    • U.S. Department of Housing and Urban Development;
    • U.S. Army Corps of Engineers;
    • White House Task Forces;
    • American Water Works Association;
    • Association of Metropolitan Water Agencies;
    • National Rural Water Association;
    • Rural Community Assistance Partnership;
    • National Association of Water Companies;
    • Association of State Drinking Water Administrators;
    • Natural Resources Defense Council; and
    • Consumers Federation of America. 
    3. USE OF TECHNOLOGY
Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
The data generated as a result of the regulatory changes will be integrated in the existing quarterly SDWIS reporting process. The collection methodology and management of SDWIS is described in the ICR entitled Public Water System Supervision Program (OMB control number 2040-0090).
    4. EFFORTS TO IDENTIFY DUPLICATION
Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
The EPA has consulted with other Federal agencies, State agencies, industry organizations, water systems, and Tribal organizations to ensure non-duplication of this information collection. To the best of the agency's knowledge, data required by the final LCRI revisions are not available from any other source.
    5. MINIMIZING BURDEN ON SMALL BUSINESSES AND SMALL ENTITIES
If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
In developing the final LCRI, EPA considered the requirement of the Small Business Regulatory Enforcement Fairness Act (SBREFA) to minimize the burden of information collections on small entities. Small entities include “small businesses,” “small organizations” and “small government jurisdictions,” and, are defined as follows:
    • A small business is any business that is independently owned and operated and not dominant in its field, as defined by the Small Business Administration regulations under section 3 of the Small Business Act.
    • A small organization is any non-profit enterprise that is independently owned and operated and not dominant in its field.
    • A small governmental jurisdiction is the government of a city, county, town, township, village, school district, or special district that has a population of fewer than 50,000. This definition may also include Tribal governments.
The major requirement under SBREFA is a regulatory flexibility analysis of all rules that have a “significant economic impact on a substantial number of small entities.” 
EPA considered the particular needs of small businesses, small governments, and small organizations when proposing rule changes in the LCRI. For example, EPA has prepared a Regulatory Flexibility Act analysis for the rule, which can be found in the Economic Analysis for the final LCRI. EPA recognizes that many water systems are small entities; therefore, the final LCRI reduces to the extent practicable and appropriate the burden on PWSs, especially smaller systems. The regulations include the following examples of reduced burden for small systems:
    • Different monitoring, compliance, or reporting requirements or schedules that take into account the resources available to smaller water systems. 
    • Consolidated or simplified compliance and reporting requirements.
    • No unnecessary or redundant requirements.

	The final LCRI incorporates additional flexibility for small CWSs serving 3,300 or fewer people and all NTNCWSs by allowing these entities to select, in consultation with their State, the compliance option that best protects public health, recognizing the unique nature of these systems. This flexibility applies to CWSs serving 3,300 or fewer people and all NTNCWSs that exceed the lead action level of 0.010 mg/L. The compliance options for these systems after an action level exceedance include CCT; provision, monitoring, and maintenance of POU devices; and replacement of all lead-bearing materials. Small systems can work with their State to identify the treatment technique most appropriate to reduce drinking water lead exposure.
    6. CONSEQUENCES OF LESS FREQUENT COLLECTION
Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
EPA has considered a wide range of alternatives for frequency of data collection. EPA has chosen to require the least frequent collection that remains consistent with the overall goal of protecting public health. If data are collected less frequently, States may not identify in a timely fashion significant sources of lead exposure that might threaten the health and safety of drinking water consumers. 
Systems must take steps to identify lead content service lines, as part of the service line inventory requirements of the final LCRI, in order to inform their consumers of the potential health risks from drinking water lead exposure and steps they can take to mitigate their exposure including participating in the system’s service line replacement program. Both the inventory information and the service line replacement plan are critical in the implementation of the mandatory service line replacement requirements of the final LCRI. The replacement of the lead content service lines will significantly reduce drinking water customer exposure to lead. 
    7. GENERAL GUIDELINES
Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.
Apart from the two instances noted below, this ICR will not violate the guidelines codified under 5 CFR 1320.5(d)(2).  Records are required to be retained for a period greater than three years. In particular, the 1991 LCR requires all PWSs to retain on their premise original records of all sampling data and analyses, reports, surveys, letters, evaluations, schedules and any other information required by the State for no fewer than 12 years. Primacy agencies are subject to the same record retention period, except that States are required to retain information relating to the decisions in §142.14(d)(8) indefinitely, until a new decision, determination, or designation has been issued. The Agency justified these record retention periods and received approval for them under the original 1991 LCR ICR. 

8. PUBLIC COMMENT AND CONSULTATIONS
8a. Public Comment
If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the Agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the Agency in response to these comments. Specifically address comments received on cost and hour burden.
To comply with the 1995 Amendments to the Paperwork Reduction Act, the agency is soliciting public comment on this final ICR during a 30-day public comment period. In the Federal Register notice for the final rule, the EPA requested comment on the estimated respondent burden and other aspects of this information collection. Comments received were considered by the agency and used to adjust the burden and costs estimates presented in the final ICR prior to submission to the OMB.
8b. Consultations
Describe efforts to consult with persons outside the Agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
This section provides a summary of the EPA’s engagements and consultations that occurred as part of the LCRR Review and additional engagements and consultations that the EPA held to support the development of the LCRI. The EPA’s summaries and presentation materials, or other documents from meetings and consultations discussed in these sections are available in the docket for the final rule under EPA-HQ-OW-2022-0801 at https://www.regulations.gov. For the consultations specifically conducted to support the final LCRI also see Section VII of the final LCRI Federal Register Notice.
LCRR Review
On January 15, 2021, the EPA published the “National Primary Drinking Water Regulation: Lead and Copper Rule Revisions” (86 FR 4198; USEPA, 2021b) (LCRR) with an effective date of March 16, 2021, and a compliance date of January 16, 2024. On January 20, 2021, President Biden issued the “Executive Order on Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis” (Executive Order 13990). 
Section 1 of Executive Order 13990 States that it is “the policy of the Administration to listen to the science, to improve public health and protect our environment, to ensure access to clean air and water; … and to prioritize both environmental justice and the creation of the well-paying union jobs necessary to deliver on these goals.” Executive Order 13990 directs the heads of all Federal agencies to immediately review regulations that may be inconsistent with, or present obstacles to, the policy it establishes. On March 12, 2021, the EPA published the National Primary Drinking Water Regulations: Lead and Copper Rule Revisions; Delay of Effective Date (86 FR 14003; USEPA, 2021c), which delayed the effective date of the LCRR from March 16, 2021, to June 17, 2021. On the same day, the EPA published the National Primary Drinking Water Regulations: Lead and Copper Rule Revisions; Delay of Effective and Compliance Dates (86 FR 14063; USEPA, 2021d), which final further delaying the effective date of LCRR to December 16, 2021 to allow the EPA to “conduct a review of the LCRR and consult with stakeholders, including those who have been historically underserved by, or subject to discrimination in, Federal policies and programs prior to the LCRR going into effect” (86 FR 14063; USEPA, 2021d). On June 16, 2021, the EPA published a final rule, the National Primary Drinking Water Regulations: Lead and Copper Rule Revisions; Delay of Effective and Compliance Dates (86 FR 31939; USEPA, 2021e), which delayed the LCRR effective date until December 16, 2021, and the compliance date until October 16, 2024. While the LCRR was delayed, the EPA engaged with stakeholders to better understand their thoughts and concerns about the LCRR.
The EPA hosted a series of virtual engagements from April to August 2021 to obtain public input on the review of the LCRR. The EPA also opened a docket, from April 5, 2021 to July 30, 2021, to accept written comments, suggestions, and data from the public. Summaries of these engagements, including summaries of the meetings and written comments, can be found in the docket, EPA-HQ-OW-2021-0255 at https://www.regulations.gov/. Recordings of the public listening sessions and community, Tribal, and national stakeholder association roundtables can also be found in the docket. The virtual engagement meetings included two public listening sessions, ten community roundtables, a Tribal roundtable, a national stakeholder association roundtable, a national co-regulator meeting, and a meeting with organizations representing elected officials. A diverse group of individuals and associations provided feedback through these meetings and the docket, including people from communities impacted by lead in drinking water, local governments, water utilities, Tribal communities, public health organizations, environmental groups, environmental justice organizations, and co-regulators.
The EPA specifically sought engagement with communities that have been disproportionately impacted by lead in drinking water, especially lower-income people and communities of color that have been underrepresented in past rule-making efforts. The EPA hosted roundtables with individuals and organizations from Pittsburgh, Pennsylvania; Newark, New Jersey; Malden, Massachusetts; Washington, D.C.; Newburgh, New York; Benton Harbor and Highland Park, Michigan; Flint and Detroit, Michigan; Memphis, Tennessee; Chicago, Illinois; and Milwaukee, Wisconsin. These geographically focused roundtables included a range of participants including local government entities, community organizations, environmental groups, local public water utilities, and public officials. The EPA worked with community representatives to develop meeting agendas that reflected community priorities. Each community roundtable included a presentation by local community members. The EPA held a separate roundtable with representatives from Tribes and Tribal communities. Participants in all roundtables were invited to share diverse perspectives with the agency through verbal discussion and a chat feature. The EPA obtained detailed, valuable feedback from these engagements, which often focused on the lived experiences of people impacted by lead in drinking water.
On December 17, 2021, the EPA published its findings from the review (86 FR 71574, December 17, 2021, USEPA, 2021a). The EPA identified priority improvements for a revised rule known as the Lead and Copper Rule Improvements (or the LCRI) including:
    • Proactive and equitable lead service line replacement,
    • Strengthening compliance tap sampling to better identify communities most at risk of lead in drinking water and to compel lead reduction actions, and
    • Reducing the complexity of the regulation by improving the action and trigger level construct. 
Consultations and Engagements to Support the Development of the Final LCRI
The EPA held consultations and engagements during September 2022 through August 2023 to obtain additional feedback on areas the EPA identified for improvement during the LCRR Review. A summary of these consultations and engagements is provided below. Also, see Section VII of the final LCRI Federal Register Notice for additional detail on the consultations and engagements.
Small Business Stakeholders       
On September 12, 2022, the EPA conducted a Small Business Advocacy Review (SBAR) pre-panel outreach meeting to solicit input from 11 small entity representatives (SERs) on the potential small systems implications of the forthcoming final LCRI. On November 29, 2022, the EPA convened a second SBAR outreach panel to solicit further input from SERs. Through these panels, the SERs provided feedback on key areas, including achieving 100 percent LSLR in small systems; compliance with the revised tap sampling protocols; compliance with a revised AL; reducing rule complexity; sustained elevated lead levels; public notice requirements; considerations for schools; and child care facilities; and small system flexibility. The SBAR panel submitted its report to the EPA on May 31, 2023. For more information about the SBAR panel, visit http://www.epa.gov/reg-flex/potential-sbar-panel-national-primary-drinking-water-regulation-lead-and-copper-rule.
Public Meeting on Environmental Justice
The EPA held two public meetings related to environmental justice and the development of the final LCRI on October 25, 2022 and November 1, 2022. These sessions provided opportunities for EPA to share information about the upcoming LCRI rulemaking and for individuals to offer input on environmental justice considerations related to the rule. During the meeting, EPA presented a brief overview of lead health effects, lead occurrence in drinking water, and the SDWA process for developing a drinking water regulation, in particular highlighting the EJ-related components. EPA received public input through verbal and written public comments, as well as interactive polling responses. THE EPA received a total of 30 public comments during the 60-day post meeting comment period. Public comments included incorporating equity into 100 percent LSLR replacement goals, methods of identifying and prioritizing disadvantaged communities who are disproportionately impacted by lead in in drinking water for LSLR, and methods of overcoming customers’ financial and access barriers to full LSLR. A summary report of the views expressed during both environmental justice consultations is available in the docket (EPA-HQ-OW-2022-0801) at www.regulations.gov.

Consultation with Tribal Governments
The EPA initiated consultations and coordination with federally recognized Indian Tribes to obtain input on the Agency’s final LCRI, pursuant to Executive Order 13175, Consultation and Coordination with Indian Tribal Governments (Executive Order 13175). The EPA signed a Tribal consultation notification letter inviting Tribal officials to participate in consultation and coordination events and provide comments to the EPA, and emailed this letter to all 574 federally-recognized tribal leaders at that time. In addition to the consultation invitation letter, the EPA provided a consultation and coordination plan background information, and an invitation to two national informational webinars for Tribal governments. All Tribal consultation materials were made available via the EPA’s Tribal Consultation Opportunities Tracking System (https://tcots.epa.gov).  
The national informational webinars were held on October 27, 2022, and November 9, 2022. Consistent with the EPA Policy on Consultation and Coordination with Indian Tribes (May 4, 2011), the EPA consulted with Tribal officials to gain an understanding of Tribal views of key areas of the final LCRI. As part of the meeting, the EPA representatives presented background information on the pre-2021 LCR and LCRR regulations regarding lead and copper content in drinking water. The EPA also presented on the rule considerations for the final LCRI. During the consultation process, the EPA requested input from Tribal governments on considerations to inform the development of the final LCRI, including elements related to potential regulatory requirements and suggestions that would assist Tribal governments in implementing and complying with the rule. Four specific areas of the final rule on which the EPA requested input included achieving 100 percent LSLR, tap sampling and compliance, reducing rule complexity, and small system flexibility. 
A total of 11 Tribal representatives participated in the two webinars. Webinar participants provided verbal comments, but the EPA did not receive any written consultation comments from Tribal organizations during the comment period that followed the webinars.
SAB Consultation 
The EPA consulted with the 37 members of the Science Advisory Board (SAB) on tools, indicators, and measures for use in future analyses to determine environmental justice impacts of LSL presence and replacement in drinking water systems. Prior to the meeting, which was held on November 3, 2022, the EPA provided the charge to the SAB and shared the Agency’s preliminary analyses and draft results on case studies for three cities to help inform the Agency’s environmental justice analysis for the final LCRI (USEPA, 2022). The SAB provided its final report to the EPA Administrator on December 20, 2022 regarding the Agency’s environmental justice analysis for LCRI (USEPA SAB, 2022).
NDWAC Consultation  
On December 1, 2022, the EPA held a public meeting with the National Drinking Water Advisory Council (NDWAC). the EPA provided background on lead in drinking water and the LCR, an overview of the LCRR published in January 2021, annualized cost estimates from the LCRR EA, and a summary of the outcome of the EPA’s review of the LCRR. The NDWAC provided key input on four key areas: achieving 100 percent LSLR, tap sampling and compliance, reducing rule complexity, and small system flexibility. The public was also given an opportunity to provide their comments to the NDWAC. A summary of the NDWAC consultation is available in the NDWAC Summary Report and is available in the docket for this rule. The EPA carefully considered NDWAC recommendations during the development of the final LCRI.
On January 31, 2024, the EPA consulted with the NDWAC again. During the consultation the EPA provided general background on lead in drinking water and the LCR. The EPA provided an overview of the final LCRI including discussing the key revisions in the final rule. The EPA carefully considered the information provided by the NDWAC during the development of the final LCRI. A summary of the NDWAC input from that meeting is available in the NDWAC Summary Report and is also available in the docket for this rule.
2022 Federalism/Unfunded Mandates Reform Act (UMRA) Consultation
The Federalism Consultation began on October 13, 2022 and ended on December 13, 2022. On September 29, 2022, the Director of the Office of Ground Water and Drinking Water (OGWDW), Jennifer McLain, signed a Federalism consultation notification letter inviting State and local government officials as well as their representative associations to participate in a meeting and consultation and provide comments to the EPA during the consultation process. The EPA sent this letter to a number of State and local agencies as well as several water and utility professional organizations that may have state and local government members.  
The EPA held the Federalism and UMRA meeting on October 13, 2022. During the meeting, the EPA presented background information and questions for feedback on key areas of the final rule. The EPA specifically requested input on the following key rule areas: achieving 100 percent LSLR, tap sampling and compliance, reducing rule complexity, and small system flexibility. Fifteen organizations, as well as several associations with expertise in drinking water, were represented at the Federalism/UMRA consultation meeting. Although this virtual briefing was for intergovernmental association staff only, participants were able to schedule follow-up briefings for their memberships and were encouraged to forward the briefing information and materials to their members. The EPA provided a 60-day public comment period following the October 13, 2022 meeting.    
Meetings with ASDWA
The EPA met with the Association of State Drinking Water Administrators (ASDWA) on October 5, 2022 and November 2, 2022 to solicit feedback from State co-regulators on the development of LCRI. The EPA presented background regarding the pre-2021 LCR, an overview of LCRR, and cost information for actions to reduce drinking water lead levels. ASDWA and State co-regulators provided feedback on how quickly systems can achieve 100 percent LSLR, factors that impact a system’s rate of LSLR, barriers to engaging customers for full LSLR, how systems can ensure equity in replacements, tap sampling and compliance and opportunities to reduce complexity mainly around the action level and trigger level construct. In addition, ASDWA and State co-regulators provided input on CCT, WQPs, find-and-fix provisions, school and childcare sampling, public education, and SDWIS capabilities to track data.
Department of Health and Human Services
	In accordance with section 1412(d) of SDWA, the agency consulted with the Department of Health and Human Services (HHS). On August 18, 2023, the EPA consulted with the HHS on the final LCRI and on July 15, 2024, the EPA consulted with the HHS on the final rule. The EPA received and considered comments from the HHS for both the proposal and final rule through the interagency review process under Executive Order 12866: Regulatory Planning and Review. Summaries of the consultation meetings with the HHS can be found in the docket (EPA-HQ-OW-2022-0801).

Public Water Systems 
On December 7, 2023, the EPA sent a questionnaire to nine water systems regarding the burden and cost to develop and maintain a service line inventory under the LCRR. EPA requested feedback by February 28, 2023 and received responses from three water systems, Grand Rapids, Michigan; Pittsburgh, Pennsylvania; and Cincinnati, Ohio (available in the docket at EPA-HQ-OW-2022-0801 at www.regulations.gov). The EPA used the information from these three water systems among other sources to help develop burden and cost related to service line inventory updates and validation.
    8. PAYMENTS OR GIFTS TO RESPONDENTS
Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.
The Agency does not intend to provide payments or gifts to respondents as part of this collection. 
    9. ASSURANCE OF CONFIDENTIALITY
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or Agency policy. If the collection requires a systems of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.
No confidential information will be collected as a result of this ICR. 
    10. JUSTIFICATION FOR SENSITIVE QUESTIONS
Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the Agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
No questions of a sensitive nature are included in any of the information collection requirements outlined in this ICR.
    11. RESPONDENT BURDEN HOURS & LABOR COSTS
Provide estimates of the hour burden of the collection of information. The statement should:
    • Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Generally, estimates should not include burden hours for customary and usual business practices.
    • If this request for approval covers more than one form, provide separate hour burden estimates for each form and the aggregate the hour burdens.
    • Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included as O&M costs under non-labor costs covered under question 13.
12a. Respondents/NAICS Codes
Data associated with this ICR are collected and maintained at the PWS, State, Tribal, and Federal levels. Respondents include:
    • Owners/operators of PWSs, who must report to their primacy agency.
    • Primacy agencies, and the EPA Regions that act as primacy agencies for States, territories, and Tribal lands that do not have primacy.
The North American Industry Classification System (NAICS) code for privately owned PWSs is 22131. The NAICS codes for State agencies that include drinking water programs are 92411 (Administration of Air and Water Resources and Solid Waste Management Programs) or 92312 (Administration of Public Health Programs). Ancillary systems (systems where providing water is ancillary to a primary business, e.g., mobile home parks) cannot be categorized in a single NAICS code. For ancillary systems, the NAICS code is that of the primary establishment or industry.
12b. Information Requested
For activities occurring in the first three years of final LCRI implementation, Exhibit 1 and Exhibit 2 list the data items required from PWSs and States, respectively. 

Exhibit 1. PWSs Reporting Data Items
Requirement
Requirement Category
Frequency
System reads and understands the LCRI
Implementation activity
Once
System assigns personnel and resources for rule implementation
Implementation activity
Once
System attends training and receives technical assistance from the State during implementation of the LCRI
Implementation activity
Once
System reviews records for lead connector material to prepare the updated initial inventory (baseline inventory)
Service Line Inventory
Once
System submits the updated initial inventory with lead connector information (baseline invintory)
Service Line Inventory
Once
System conducts normal operations and field investigations to update unknown service lines
Service Line Inventory
Annually until all service lines are identified
System prepares a service line replacement plan and submits to the State
Service Line Replacement Plan
Once
Systems include information on deferred deadline and associated replacement rate in the SLR plan 
Service Line Replacement Plan
Once
Systems identify funding options for full SLRs
Service Line Replacement Plan
Once
System develops public education materials for customers with service lines with lead, GRR, or unknown material and submits material to State for review
Public Education
Once
System distributes public education materials to customers with service lines with lead, GRR, or unknown material
Public Education
Annually until all service lines are identified and lead service lines are replaced
System updates a tap sampling plan and submits to the State
Tap Sampling
Once



Exhibit 2. State/Primacy Agency Reporting Data Items
Requirement
Requirement Category
Frequency
State adopts the rule and develops program to implement the LCRI
Implementation activity
Once
State modifies their data system while implementing the LCRI
Implementation activity
Once
State provides internal staff with training during implementation of the LCRI
Implementation activity
Once
State provides system staff with training and technical assistance during implementation of the LCRI
Implementation activity
Once
State reviews updated initial inventories (baseline inventories) with lead connector information
Service Line Inventory
Once
State reviews service line replacement plan
Service Line replacement plan
Once
State reviews information on deferred deadline and associated replacement rate in the SLR plan and determine fastest feasible rate
Service Line Replacement Plan
Once
State provides systems with a public education template and reviews developed material
Public Education
Once
State reviews tap sampling plan
Tap Sampling
Once
12c. Respondent Activities
Implementation activity 
Activities for Systems
Systems must conduct planning and mobilize for the implementation of the final LCRI, including 1) reading and understanding the rule, 2) assigning personnel and resources, and 3) dedicating staff to attend training and receive technical assistance from the State.
Activities for Primacy Agencies
States must 1) adopt the rule into State regulations and develop an implementation program, 2) modify data management systems, 3) train State staff, and 4) provide training and technical assistance to systems. 
Developing and reporting the service line inventory
Activities for Systems
	Systems must review and update their initial service line inventory (called the baseline inventory) with information on lead connectors developed through the use of the specified sources in the rule or by methods approved or required by the State. They also continue to investigate unknown service lines of unknown material during normal operations to inform the development of the updated initial their service line inventory (baseline inventory). 
Activities for Primacy Agencies
	States must review the submission of the updated initial service line inventory (baseline inventory) with lead connector information. 
Developing and reporting the service line replacement plan
Activities for Systems
	Systems with lead, GRR, and/or unknown service lines must create and submit to the State a lead service line replacement plan. The plan would include the following elements: 
    • A strategy for determining the composition of lead status unknown service lines in its inventory.
    • A standard operating procedure for conducting full service line replacement.
    • A strategy for informing customers before a full or partial service line replacement. 
    • A funding strategy for conducting service line replacement.  Where the water system intends to charge customers for the cost to replace all or a portion of the service line because it is authorized or required to do so under State or local law or water tariff agreement, the funding strategy must include a description of whether and how the water system intends to assist customers who are unable to pay to replace the portion of the service line they own. 
    • A procedure for consumers and customers to flush service lines and premise plumbing of particulate lead following a disturbance and post-replacement.

    • A strategy to prioritize service line replacement based on factors including, but not limited to, known lead and GRR service lines and community-specific factors, such as populations disproportionately impacted by lead and populations most sensitive to the effects of lead.

    • A communication strategy to inform both residential and non-residential customers and consumers (e.g. property owners, renters, and tenants) with lead, GRR, and unknown material  service lines about the replacement plan and program.

    • dentification of any laws, regulations, and/or water tariff agreements relevant to the water system’s ability to gain access to conduct full replacement.

    • For systems that identify any lead-lined galvanized service lines in their inventory, a strategy to determine the extent of the use of lead-lined galvanized service lines in the distribution system.
    • For systems eligible for and requesting a deferred SLR deadline the initial SLR plan must also include: (1) documentation of the system’s eligibility for a deferred deadline; (2) documentation detailing the system’s need for completing mandatory SLR under a deferred deadline, including identification of the deferred deadline and the associated cumulative average replacement rate considered to be the fastest feasible, the annual number of replacements required, the length of time, and the date of completion and rate, ; and (3) information supporting the system’s determination that replacing lead and GRR service lines at a faster rate is not feasible.

Activities for Primacy Agencies
	States must review the service line replacement plans submitted by systems. 
Developing and distributing public education material
Activities for Systems
	Systems with lead, GRR, and/or unknown service lines must develop public education material, submit the material to the States, and distribute the material to customers. The public education material must provide customers served by lead, GRR, or unknown service lines with information on the health effects and sources of lead in drinking water, how to have water tested for lead, actions customers can take to reduce exposure to lead, information about the opportunities for service line replacement and opportunities to have the material of unknown service lines identified, and information on how to obtain a copy or view the service line inventory and service line replacement plan.
Activities for Primacy Agencies
	The EPA assumed that States would incur burden and cost for providing systems that have LSL, GRR, and/or unknown material service lines with templates for the required public education outreach. States must also review the public education material submitted by the systems.
Updating and submitting the tap sampling plan
Activities for Systems
Systems must submit updated tap sampling plans to the State prior to the initial monitoring period under the final rule. The revised plans must reflect the final rule changes to the protocol that water systems must use for tap sampling. Water systems are required to collect first- and fifth-liter samples at sites with LSLs and use the higher of the two values when calculating the 90th percentile. 

Activities for Primacy Agencies
	States must review the tap sampling plans submitted by systems.
Additional Activities Required by Final LCRI
Exhibit 1-1 in Chapter 1, Section 1.1 of the EPA’s Economic Analysis of the final LCRI (available in the docket at EPA-HQ-OW-2022-0801 at www.regulations.gov) summarizes the additional activities required by the final LCRI that will take place after the initial three years covered by this ICR. 
12d. Respondent Burden Hours and Labor Costs
This section describes the estimates of burden and direct costs to water systems and states associated with the regulatory changes.
This ICR provides estimates of the incremental burdens to comply with the LCR as amended by the final LCRI. The LCRI implementation period overlaps the LCRR renewal and supplemental ICR and supersedes or removes some LCRR requirements. As a result, the initial burden and cost estimates for the LCRI double-count burden estimates in the requested Information Collection Request for the Lead and Copper Rule Revisions (OMB Control Number 2040-0297; EPA Tracking Number 2606.03). The EPA provides an estimate of the double counting and subtracts that amount from the final net estimates.
The burden and cost estimates in this ICR are based on the calculations documented in the Economic Analysis for the Final Lead and Copper Rule Improvements (available in the docket at EPA-HQ-OW-2022-0801 at www.regulations.gov). Major underlying burden assumptions, data sources, and calculations are detailed in Chapter 4 of that document.
For the final LCRI the Agency considered a wide range of alternatives for frequency of data collection and chose the option that requires the least frequent collection possible while still protecting public health. The collection schedule for the first three years assumes that public water system rule implementation (read rule, assign staff, attend training), and public education materials development activities would take place in the first year, the service line replacement plan would be developed and submitted in the third year, and the implementation of the service line inventory and public education distribution requirements are spread uniformly over the first three years. States are assumed to conduct implementation activities, review initial service line inventory updates with lead connector information, and review annual service line inventory updates across each of the first three years. States would also provide templates to systems for public education on service lines with lead, GRR or unknown content and review the systems’ developed materials in the first year covered by this ICR. They would review the systems’ SLR plans in the third year.
Burden to Public Water Systems
During the three-year period covered by this ICR, public water systems will conduct one-time startup activities that include the following:
    • reading and understanding the rule;
    • assigning personnel and resources for rule implementation;
    • attending training and receiving technical assistance from the State;
    • updating and submitting to the State a service line inventory that includes lead connector information; 
    • preparing and submitting to the State the SLR plans; and
    • developing and submitting to the State for approval public education materials for customers with lead, GRR, and unknown service lines that must be delivered annually.

	During this time period, public water systems will also conduct on-going activities that include the following:
    • collect service line information during normal operations and conduct targeted field operations to update the material status of unknown service lines;
    • update and submit annually the service line inventory as unknown service lines are identified; and 
    • distribute public education materials to customers with lead, GRR, and unknown service lines annually.
The number of systems performing each task, shown in Exhibit 3, varies depending on estimated LSL, GRR and unknown service line presence. See Chapter 4 of the Economic Analysis for the Final Lead and Copper Rule Revisions (available in the docket at EPA-HQ-OW-2022-0801 at www.regulations.gov) for a detailed presentation of the data and formulas used in generating the burden estimates.
Exhibit 3. Total PWS Respondents, Responses, and Burden for the FINAL LCRI ICR
Requirement
Responses
Respondents
Average Burden Hours per Response per Respondent
Total Burden
System reads and understands the LCRI
66,947
66,947
4
267,788
System assigns personnel and resources for rule implementation
66,947
66,947
8
535,576
System attends training and receives technical assistance from the state during implementation of the LCRI
66,947
66,947
8
535,576
Systems review records for connector material to prepare the updated initial inventory
200,841
66,947
0.5 - 7,431
4,406,882
Systems submit the updated initial inventory with connector information
200,841
66,947
1 - 15
381,190
Systems conduct normal and field operations to update unknown service lines
14,648,784
25,562
Non-labor cost
Non-labor cost
Systems update and submit inventory to State annually
78,000
26,000
1
78,000
Systems prepare a service line replacement plan and submit it to the State
26,000
26,000
12 - 36
374,384
Systems develop public education materials for customers on service lines with lead, GRR, or unknown content and submit to States for review
26,000
26,000
7
182,000
Systems distribute public education materials for customers on service lines with lead, GRR, or unknown content
59,995,291
26,000
0.003 - 0.443
817,980
System Total
75,376,598
66,947
42 – 7,510
7,579,376
Notes: Range presented in average burden reflects differences in system type and size. Detail may not add exactly to total due to independent rounding. Results show the upper bound estimate for the number of lead lines located in NTNCWS, Chapter 4 of the EA documents a difference of approximately 5 lines between the upper- and lower-bound estimates. Aggregate respondent totals across responses will vary according to the type of responses required and the number systems reporting to a State.
Burden to States
During the three-year period cover by this ICR, States will incur burden associated with one-time startup activities that include the following:
    • adopting the rule into State regulations and developing an implementation program;
    • modifying their data system; 
    • providing internal State staff with training for implementation;
    • providing system staff with training and technical assistance;
    • reviewing updated initial inventory with lead connector information;
    • reviewing the initial SLR plan, including information on deferred deadlines;
    • providing templates and reviewing public education material for customers with lead, GRR, and unknown service lines; and
    • reviewing updated tap sampling plan.

	During this time period, States will also conduct the on-going activity of reviewing systems’ annual updates of water system inventories.

	During the three-year period (2024 to 2027), States will incur burden associated with completing the rule implementation, reviewing service line inventories, reviewing service line replacement plans, providing templates and reviewing public education materials, and reviewing tap sampling plans listed in Exhibit 4. See Chapter 4 of the Economic Analysis for the Final Lead and Copper Rule Revisions (available in the docket at EPA-HQ-OW-2022-0801 at www.regulations.gov) for a detailed presentation of the data and formulas used in generating the burden estimates.
Exhibit 4. Total State Respondents, Responses, and Burden for the FINAL LCRI ICR
Requirement
Responses
Respondents
Average Burden Hours per Response per Respondent
Total Burden
State adopts the rule and develop program to implement the LCRI
56
56
640
107,520
State modifies their data system while implementing the LCRI
56
56
740
124,320
State provides State staff with training for implementation of the LCRI
56
56
196
32,928
State provides system staff with training and technical assistance during implementation of the LCRI
56
56
800
134,400
State reviews updated initial inventories (baseline inventories) with connector information
200,841
56
1
200,841
State confers with PWS on initial planning for SLR as part of initial SLR Program activities
25,823
56
6-18
205,690
information on deferred deadline and associated replacement rate in the SLR plan and determine fastest feasible rate
5
56
.15-4.5
16
State provides templates to systems for public education on service lines with lead, GRR, or unknown content and reviews developed materials
25,823
56
0.88 - 2.38
23,767
State Total
319,663
56
2,502 – 10,325
829,482
Notes: Range presented in average burden reflects differences in system type and size. Detail may not add exactly to total due to independent rounding. Results show the upper bound estimate for the number of lead lines located in NTNCWSs, Chapter 4 of the Economic Analysis documents a difference of approximately 4 lines between the upper- and lower-bound estimates. Aggregate respondent totals across responses will vary according to the type of responses required and the number systems reporting to a state.
Cost to Public Water Systems
The labor rates associated with the system activities during the ICR period apply to all 66,947 CWSs and NTNCWSs that must comply with the final LCRI. The fully loaded labor rate estimates range from $36.56 to $57.40 per hour depending on system size. Based on these labor rates, Exhibit 5 through Exhibit 14 present the costs to systems for each of the activities conducted in the three years covered by the ICR. 
Exhibit 5. Burden and Costs for Public Water Systems for Implementaion Activities (Reading Rule, Assigning Personnel, Attending Training)
Respondent Type (service population size category)
Respondents
Burden per Response (hours)
Burden (hours)
Labor Rate (2022 USD/hour)
Cost (2022 USD)
<=100 
20,120
20
402,400
$36.56 
$14,711,691
101-500 
21,464
20
429,280
$36.56 
$15,694,420
501-1,000
6,908
20
138,160
$36.56 
$5,051,111
1,001-3,300
8,838
20
176,760
$36.56 
$6,462,322
3,301-10,000
5,188
20
103,760
$43.59 
$4,522,971
10,001-50,000
3,411
20
68,220
$46.74 
$3,188,569
50,001-100,000
572
20
11,440
$50.49 
$577,644
100,001-1,000,000
422
20
8,440
$57.40 
$484,441
>1,000,000
24
20
480
$57.40 
$27,551
System 3-year Total
66,947
not applicable
1,338,940
not applicable
$50,720,720
Annual Average
not applicable
not applicable
446,313
not applicable
$16,906,907
Notes: Detail may not add exactly to total due to independent rounding.
Exhibit 6. Burden and Costs for Public Water Systems Conducting a Records Review to Identify Lead Connectors 
Respondent service population size category and type
Responses
Burden per Response (hours)
Burden (hours)
Labor Rate (2022 USD/hour)
Cost (2022 USD)
<=100, CWS
35,196
0.51
17,796
$36.56 
$650,633
101-500, CWS
45,252
2.00
90,557
$36.56 
$3,310,756
501-1,000, CWS
15,990
5.70
91,176
$36.56 
$3,333,398
1,001-3,300, CWS
23,901
14.25
340,573
$36.56 
$12,451,319
3,301-10,000, CWS
15,078
33.06
498,494
$43.59 
$21,729,714
10,001-50,000, CWS
10,122
108.45
1,097,725
$46.74 
$51,307,121
50,001-100,000, CWS
1,713
295.59
506,342
$50.49 
$25,566,876
100,001-1,000,000, CWS
1,263
896.56
1,132,361
$57.40 
$64,995,506
>1,000,000, CWS
72
7,599.09
547,134
$57.40 
$31,404,522
<=100, NTNCWS
25,164
0.51
12,724
$36.56 
$465,181
101-500, NTNCWS
19,140
2.00
38,302
$36.56 
$1,400,333
501-1,000, NTNCWS
4,734
5.70
26,994
$36.56 
$986,886
1,001-3,300, NTNCWS
2,613
14.25
37,234
$36.56 
$1,361,253
3,301-10,000, NTNCWS
486
33.06
16,068
$43.59 
$700,401
10,001-50,000, NTNCWS
111
108.45
12,038
$46.74 
$562,645
50,001-100,000, NTNCWS
3
295.59
887
$50.49 
$44,776
100,001-1,000,000, NTNCWS
3
896.56
2,690
$57.40 
$154,384
>1,000,000, NTNCWS
n/a
n/a
n/a
n/a
n/a
System 3-year Total
200,841
not applicable
4,469,095
not applicable
$220,425,702
Annual Average
66,947
not applicable
1,489,698
not applicable
$73,475,234
Notes: Detail may not add exactly to total due to independent rounding. 
Exhibit 7. Burden and Costs for Public Water Systems to Submit Updated Inventory Based on Records Review of Lead Connectors
Respondent service population size category and type
Responses
Burden per Response (hours)
Burden (hours)
Labor Rate (2022 USD/hour)
Cost (2022 USD)
<=100, CWS
35,196
1
35,196
$36.56 
$1,286,761
101-500, CWS
45,252
1
45,252
$36.56 
$1,654,407
501-1,000, CWS
15,990
1
15,990
$36.56 
$584,592
1,001-3,300, CWS
23,901
1
23,901
$36.56 
$873,817
3,301-10,000, CWS
15,078
2
30,156
$43.59 
$1,314,521
10,001-50,000, CWS
10,122
2
20,244
$46.74 
$946,194
50,001-100,000, CWS
1,713
4
6,852
$50.49 
$345,980
100,001-1,000,000, CWS
1,263
4
5,052
$57.40 
$289,976
>1,000,000, CWS
72
4
288
$57.40 
$16,531
<=100, NTNCWS
25,164
3.75
94,365
$36.56 
$3,449,972
101-500, NTNCWS
19,140
3.75
71,775
$36.56 
$2,624,085
501-1,000, NTNCWS
4,734
3.75
17,753
$36.56 
$649,029
1,001-3,300, NTNCWS
2,613
3.75
9,799
$36.56 
$358,241
3,301-10,000, NTNCWS
486
7.5
3,645
$43.59 
$158,888
10,001-50,000, NTNCWS
111
7.5
833
$46.74 
$38,911
50,001-100,000, NTNCWS
3
15
45
$50.49 
$2,272
100,001-1,000,000, NTNCWS
3
15
45
$57.40 
$2,583
>1,000,000, NTNCWS
n/a
n/a
n/a
n/a
n/a 
System 3-year Total
200,841
not applicable
381,190
not applicable
$14,596,761
Annual Average
66,947
not applicable
127,063
not applicable
$4,865,587
Notes: Detail may not add exactly to total due to independent rounding.
Exhibit 8. Costs for Public Water Systems Identifying Unknown Service Lines Through Normal Operations and Field Investigations
Respondent service population size category and type
Responses
Non-labor Cost (2022 USD)
Cost (2022 USD)
<=100, CWS
25,227
$57.44
$1,451,509
101-500, CWS
128,819
$57.44
$7,411,974
501-1,000, CWS
125,452
$57.44
$7,218,244
1,001-3,300, CWS
479,876
$51.58
$24,815,938
3,301-10,000, CWS
952,100
$54.21
$51,746,436
10,001-50,000, CWS
2,300,765
$49.53
$114,361,653
50,001-100,000, CWS
1,091,201
$50.94
$55,775,222
100,001-1,000,000, CWS
2,559,530
$39.18
$100,726,175
>1,000,000, CWS
1,729,530
$39.18
$68,062,864
System 3-year Total
9,392,500
not applicable
$431,570,015
Annual Average
 3,130,833 
not applicable
$143,856,672
Notes: Detail may not add exactly to total due to independent rounding. The EPA assumes NTNCWS have no unknown service lines following the creation of their initial inventory. In the estimation of these costs, the EPA assumes the system will conduct field investigations over the three years covered by the ICR as described in the EPA’s “Guidance for Developing and Maintaining a Service Line Inventory” available at: https://www.epa.gov/system/files/documents/2022 08/Inventory%20Guidance_August%202022_508%20compliant.pdf.
Exhibit 9. Burden and Costs for Public Water Systems to Prepare and Submit a Service Line Replacement Plan
Respondent service population size category and type
Respondents
Burden per Response (hours)
Burden (hours)
Labor Rate (2022 USD/hour)
Cost (2022 USD)
<=100, CWS
5,453
12
65,436
$36.56 
$2,392,332
101-500, CWS
7,077
12
84,924
$36.56 
$3,104,810
501-1,000, CWS
2,596
12
31,152
$36.56 
$1,138,913
1,001-3,300, CWS
3,876
12
46,512
$36.56 
$1,700,473
3,301-10,000, CWS
3,193
20
63,860
$43.59 
$2,783,702
10,001-50,000, CWS
2,384
36
85,824
$46.74 
$4,011,371
50,001-100,000, CWS
435
52
22,620
$50.49 
$1,142,159
100,001-1,000,000, CWS
322
52
16,744
$57.40 
$961,076
>1,000,000, CWS
24
52
1,248
$57.40 
$71,633
<=100, NTNCWS
233
12
2,796
$36.56 
$102,221
101-500, NTNCWS
164
12
1,968
$36.56 
$71,950
501-1,000, NTNCWS
39
12
468
$36.56 
$17,110
1,001-3,300, NTNCWS
22
12
264
$36.56 
$9,652
3,301-10,000, NTNCWS
4
12
48
$43.59 
$2,092
10,001-50,000, NTNCWS
1
12
12
$46.74 
$561
50,001-100,000, NTNCWS
n/a
n/a
n/a
n/a
n/a
100,001-1,000,000, NTNCWS
n/a
n/a
n/a
n/a
n/a
>1,000,000, NTNCWS
n/a
n/a
n/a
n/a
n/a
System 3-year Total
25,823
not applicable
423,876
not applicable
$17,510,054
Annual Average
not applicable
not applicable
141,292
not applicable
$5,836,685
Notes: Detail may not add exactly to total due to independent rounding.
Exhibit 10. Burden and Costs for Public Water Systems to Include Information on SLR Deferred Deadline
Respondent service population size category and type
Respondents
Burden per Response (hours)
Burden (hours)
Labor Rate (2022 USD/hour)
Cost (2022 USD)
<=100, CWS
n/a
n/a
n/a
n/a
n/a
101-500, CWS
1
3
3
$36.56 
$110 
501-1,000, CWS
n/a
n/a
n/a
n/a
n/a
1,001-3,300, CWS
0.33
3
0.99
$36.56 
$36 
3,301-10,000, CWS
n/a
n/a
n/a
n/a
n/a
10,001-50,000, CWS
0.33
5
1.65
$46.74 
$77 
50,001-100,000, CWS
n/a
n/a
n/a
n/a
n/a
100,001-1,000,000, CWS
n/a
n/a
n/a
n/a
n/a
>1,000,000, CWS
3
9
27
$57.40 
$1,550 
System 3-year Total
5
not applicable
33
not applicable
$1,773
Annual Average
not applicable
not applicable
11
not applicable
$591
Notes: Detail may not add exactly to total due to independent rounding.



Exhibit 11. Burden and Costs for Public Water Systems to Include Funding Options for Full Service Line Replacements
Respondent service population size category and type
Respondents
Burden per Response (hours)
Burden (hours)
Labor Rate (2022 USD/hour)
Cost (2022 USD)
<=100, CWS
5,453
68
370,804
$36.56 
$13,556,545 
101-500, CWS
7,077
68
481,236
$36.56 
$17,593,925 
501-1,000, CWS
2,596
68
176,528
$36.56 
$6,453,840 
1,001-3,300, CWS
3,876
68
263,568
$36.56 
$9,636,011 
3,301-10,000, CWS
3,193
68
217,124
$43.59 
$9,464,587 
10,001-50,000, CWS
2,384
96
228,864
$46.74 
$10,696,990 
50,001-100,000, CWS
435
96
41,760
$50.49 
$2,108,601 
100,001-1,000,000, CWS
322
170
54,740
$57.40 
$3,141,978 
>1,000,000, CWS
24
170
4,080
$57.40 
$234,185 
System 3-year Total
25,360
not applicable
1,838,704
not applicable
$72,886,662 
Annual Average
not applicable
not applicable
612,901
not applicable
$24,295,554 
Notes: Detail may not add exactly to total due to independent rounding.


Exhibit 12. Burden and Costs for Public Water Systems to Develope and Submit Public Education Materials
Respondent service population size category and type
Respondents
Burden per Response (hours)
Burden (hours)
Labor Rate (2022 USD/hour)
Cost (2022 USD)
<=100, CWS
5,453
7
38,171
$36.56 
$1,395,527
101-500, CWS
7,077
7
49,539
$36.56 
$1,811,139
501-1,000, CWS
2,596
7
18,172
$36.56 
$664,366
1,001-3,300, CWS
3,876
7
27,132
$36.56 
$991,942
3,301-10,000, CWS
3,193
7
22,351
$43.59 
$974,296
10,001-50,000, CWS
2,384
7
16,688
$46.74 
$779,989
50,001-100,000, CWS
435
7
3,045
$50.49 
$153,752
100,001-1,000,000, CWS
322
7
2,254
$57.40 
$129,376
>1,000,000, CWS
24
7
168
$57.40 
$9,643
<=100, NTNCWS
233
7
1,631
$36.56 
$59,629
101-500, NTNCWS
164
7
1,148
$36.56 
$41,971
501-1,000, NTNCWS
39
7
273
$36.56 
$9,981
1,001-3,300, NTNCWS
22
7
154
$36.56 
$5,630
3,301-10,000, NTNCWS
4
7
28
$43.59 
$1,221
10,001-50,000, NTNCWS
1
7
7
$46.74 
$327
50,001-100,000, NTNCWS
n/a
n/a
n/a
n/a
n/a
100,001-1,000,000, NTNCWS
n/a
n/a
n/a
n/a
n/a
>1,000,000, NTNCWS
n/a
n/a
n/a
n/a
n/a
System 3-year Total
25,823
not applicable
180,761
not applicable
$7,028,788
Annual Average
not applicable
not applicable
60,254
not applicable
$2,342,929
Notes: Detail may not add exactly to total due to independent rounding.
Exhibit 13. Burden and Costs for Public Water Systems to Distribute Public Education Materials to Customers Served by Lead, GRR, and Unknown Service Lines
Respondent service population size category and type
Responses
Burden per Response (hours)
Burden (hours)
Labor Rate 2022 USD/hour)
Non-labor Cost (2022 USD)
Cost (2022 USD)
<=100, CWS
318,762
0.44
141,069
$36.56 
$0.52 
$5,324,639
101-500, CWS
1,730,843
0.11
185,407
$36.56 
$0.52 
$7,686,304
501-1,000, CWS
1,745,339
0.06
109,127
$36.56 
$0.39 
$4,665,241
1,001-3,300, CWS
6,892,579
0.03
176,988
$36.56 
$0.39 
$9,138,660
3,301-10,000, CWS
15,291,015
0.03
531,461
$43.59 
$0.39 
$29,085,628
10,001-50,000, CWS
41,110,649
0.01
457,668
$46.74 
$0.39 
$37,304,402
50,001-100,000, CWS
20,879,776
0.01
109,285
$50.49 
$0.39 
$13,600,357
100,001-1,000,000, CWS
50,041,398
0.00
165,337
$57.40 
$0.39 
$28,860,179
>1,000,000, CWS
38,972,060
0.00
101,236
$57.40 
$0.39 
$20,896,140
<=100, NTNCWS
699
1
699
$36.56 
$0.09 
$25,616
101-500, NTNCWS
492
1
492
$36.56 
$0.09 
$18,030
501-1,000, NTNCWS
117
1
117
$36.56 
$0.09 
$4,288
1,001-3,300, NTNCWS
66
1
66
$36.56 
$0.09 
$2,419
3,301-10,000, NTNCWS
12
1
12
$43.59 
$0.09 
$524
10,001-50,000, NTNCWS
3
1
3
$46.74 
$0.09 
$140
50,001-100,000, NTNCWS
n/a
n/a
n/a
n/a
n/a
n/a
100,001-1,000,000, NTNCWS
n/a
n/a
n/a
n/a
n/a
n/a
>1,000,000, NTNCWS
n/a
n/a
n/a
n/a
n/a
n/a
System 3-year Total
176,983,809
not applicable
1,978,966
not applicable
not applicable
$156,612,566
Annual Average
58,994,603
not applicable
659,655
not applicable
not applicable
$52,204,189
Notes: Detail may not add exactly to total due to independent rounding.
Exhibit 14. Burden and Costs for Public Water Systems to Update and Submit Tap Sampling Plan to State
Respondent service population size category and type
Responses
Burden per Response (hours)
Burden (hours)
Labor Rate 2022 USD/hour)
Cost (2022 USD)
<=100, CWS, no service lines with lead content or GRR
6,279
2
12,558
$36.56 
$459,119
<=100, CWS, service lines with lead content or GRR
5,453
8
43,624
$36.56 
$1,594,888
101-500, CWS, no service lines with lead content or GRR
8,007
2
16,014
$36.56 
$585,470
101-500, CWS, service lines with lead content or GRR
7,077
8
56,616
$36.56 
$2,069,873
501-1,000, CWS, no service lines with lead content or GRR
2,734
2
5,468
$36.56 
$199,909
501-1,000, CWS, service lines with lead content or GRR
2,596
8
20,768
$36.56 
$759,275
1,001-3,300, CWS, no service lines with lead content or GRR
4,091
2
8,182
$36.56 
$299,133
1,001-3,300, CWS, service lines with lead content or GRR
3,876
8
31,008
$36.56 
$1,133,648
3,301-10,000, CWS, no service lines with lead content or GRR
1,833
4
7,332
$43.59 
$319,607
3,301-10,000, CWS, service lines with lead content or GRR
3,193
16
51,088
$43.59 
$2,226,962
10,001-50,000, CWS, no service lines with lead content or GRR
990
4
3,960
$46.74 
$185,088
10,001-50,000, CWS, service lines with lead content or GRR
2,384
16
38,144
$46.74 
$1,782,832
50,001-100,000, CWS, no service lines with lead content or GRR
136
4
544
$50.49 
$27,468
50,001-100,000, CWS, service lines with lead content or GRR
435
16
6,960
$50.49 
$351,434
100,001-1,000,000, CWS, no service lines with lead content or GRR
99
6
594
$57.40 
$34,095
100,001-1,000,000, CWS, service lines with lead content or GRR
322
20
6,440
$57.40 
$369,644
>1,000,000, CWS, no service lines with lead content or GRR
n/a
n/a
n/a
n/a
n/a
>1,000,000, CWS, service lines with lead content or GRR
24
20
480
$57.40 
$27,551
<=100, NTNCWS, no service lines with lead content or GRR
8,155
2
16,310
$36.56 
$596,291
<=100, NTNCWS, service lines with lead content or GRR
233
8
1,864
$36.56 
$68,148
101-500, NTNCWS, no service lines with lead content or GRR
6,216
2
12,432
$36.56 
$454,512
101-500, NTNCWS, service lines with lead content or GRR
164
8
1,312
$36.56 
$47,967
501-1,000, NTNCWS, no service lines with lead content or GRR
1,539
2
3,078
$36.56 
$112,531
501-1,000, NTNCWS, service lines with lead content or GRR
39
8
312
$36.56 
$11,407
1,001-3,300, NTNCWS, no service lines with lead content or GRR
849
2
1,698
$36.56 
$62,079
1,001-3,300, NTNCWS, service lines with lead content or GRR
22
8
176
$36.56 
$6,435
3,301-10,000, NTNCWS, no service lines with lead content or GRR
158
4
632
$43.59 
$27,549
3,301-10,000, NTNCWS, service lines with lead content or GRR
4
16
64
$43.59 
$2,790
10,001-50,000, NTNCWS, no service lines with lead content or GRR
36
4
144
$46.74 
$6,730
10,001-50,000, NTNCWS, service lines with lead content or GRR
1
16
16
$46.74 
$748
50,001-100,000, NTNCWS, no service lines with lead content or GRR
1
4
4
$50.49 
$202
50,001-100,000, NTNCWS, service lines with lead content or GRR
n/a
n/a
n/a
n/a
n/a
100,001-1,000,000, NTNCWS, no service lines with lead content or GRR
1
6
6
$57.40 
$344
100,001-1,000,000, NTNCWS, service lines with lead content or GRR
n/a
n/a
n/a
n/a
n/a
>1,000,000, NTNCWS, no service lines with lead content or GRR
n/a
n/a
n/a
n/a
n/a
>1,000,000, NTNCWS, service lines with lead content or GRR
n/a
n/a
n/a
n/a
n/a
System 3-year Total
66,947
not applicable
347,828
not applicable
$13,823,729
Annual Average
not applicable
not applicable
115,943
not applicable
$4,607,910
Notes: Detail may not add exactly to total due to independent rounding. Note system size strata with n/a in data cells have no systems in the size category.
Exhibit 15. Public Water System Total Burden and Costs for the Final LCRI ICR 
Requirement
Burden (Hours)
Labor Cost (2022 USD)
Non-labor Cost (2022 USD)
Total Cost (2022 USD)
System start-up activities (read rule, assign staff, attend training)
1,338,940
$50,720,720
$0
$50,720,720
Systems review records for connector material to prepare the updated initial inventory
4,469,095
$220,425,702
$0
$220,425,702
Systems submit the updated initial inventory with connector information
381,190
$14,596,761
$0
$14,596,761
Systems conduct normal and field operations to update unknown service lines
0
$0
$431,570,015
$431,570,015
Systems develop and submit an SLR plan
423,876
$17,510,054
$0
$17,510,054
Systems include information on deferred deadline and associated replacement rate in the SLR plan 
33
$1,773
$0
$1,773
Systems identify funding options for full SLRs
1,838,704
$72,886,662
$0
$72,886,662
Systems develop public education materials for customers on service lines with lead, GRR, or unknown content and submit to primacy agencies for review
180,761
$7,028,788
$0
$7,028,788
Systems distribute public education materials for customers on service lines with lead, GRR, or unknown content
1,978,966
$87,823,986
$68,788,580
$156,612,566
Systems update and submit tap sampling plan
347,828
$13,823,729
$0
$13,823,729
Total
              10,959,392 
$484,818,175
$500,358,595
$985,176,770

The total burden and cost estimates in Exhibit 15 partially double count the requested burden and costs for the LCRR in the Information Collection Request for the Lead and Copper Rule Revisions (OMB Control Number 2040-0297, EPA Tracking Number 2606.03). That request covered system and State burdens from January 1, 2024, through December 31, 2026, for the following groups of data collection and reporting activities under the LCRR: the normal operations to update unknown service lines, the development and submission of a service line replacement plan, the development, submission and distribution of public education materials for customers on service lines with lead, GRR, or unknown service lines. The overlap period is 16 of the 36 months. Therefore, the EPA applied a multiplicative factor of 16/36 to the LCRR ICR total burden and cost estimates to estimate the potential overlap. Exhibit 16 shows the adjustments the EPA used to estimate the final LCRI burden and costs net of the double counting. The increase in responses and non-labor costs with the decrease in burden reflect refinements in the underlying assumptions used to estimate the cost of normal investigations of unknown service lines.
Exhibit 16. Public Water System Net Total and Average Annual Burden and Costs for the Final LCRI ICR
Item
Responses
Total Burden
Labor Costs
(2022 USD)
Non-labor Costs
(2022 USD)
Total Costs
(2022 USD)
[a] Total for LCRR ICR Renewal (USEPA 2022) – All Activities
166,068,857
25,197,612
$1,080,398,986
$723,039,890
$1,803,438,877
[b] Estimated Overlap with LCRR ICR Renewal ([a] x 16/36)
              73,808,381 
               11,198,939 
$480,177,327
$321,351,062
$801,528,390
[c] Total for final LCRI ICR – All Activities
187,122,790
10,959,392
$484,818,175
$500,358,595
$985,176,770
[d] Net Total for final LCRI ICR – All Activities ([c] – [b])
            113,314,409 
           -239,546
$4,640,847
$179,007,532
$183,648,380
Net Average Annual for final LCRI ICR – All Activities ([d]/3)
              37,771,470 
          -79,849
$1,546,949
$59,669,177
$61,216,127


Cost to States
Fifty-six primacy agencies, referred to as States in this ICR, will review and implement the final LCRI, which includes 49 states, 5 territories, 1 Tribe, and the EPA.4 The fully loaded labor rate applied to State costs for the three years covered in this ICR is $59.99 per hour, in 2022 USD. Based on this labor rate, the total cost to primacy agencies for implementation activities (adopting the rule, modifying data systems, providing training to internal and system staff, and technical assistance to PWSs) is $23,944,566 (56 agencies x 399,168 hours/agency x $59.99/hour), an average of $7,981,522 per year. Exhibit 17 presents the labor costs to States for reviewing the updated initial inventories with the lead connector information. Exhibit 18 presents the labor cost to States for conferring on and reviewing service line replacement plans. Exhibit 19 presents the labor cost to States to review information on deferred deadline and associated replacement rate in the SLR plan and determine fastest feasible rate. Exhibit 20 presents the labor costs to States for providing public education templates and reviewing material submitted by systems. Exhibit 21 presents the labor costs to States for reviewing the updated tap sampling plans from systems.
Exhibit 17. Burden and Costs for States to Review Inventories with Lead Connector Information
System Type (service population size category, type)
Responses (Reviews)
Burden per Response (hours)
Burden (hours)
Labor Rate (2022 USD/hour)
Cost (2022 USD)
<=100 
60,360
1
60,360
$59.99 
$3,620,766
101-500 
64,392
1
64,392
$59.99 
$3,862,631
501-1,000
20,724
1
20,724
$59.99 
$1,243,154
1,001-3,300
26,514
1
26,514
$59.99 
$1,590,474
3,301-10,000
15,564
1
15,564
$59.99 
$933,625
10,001-50,000
10,233
1
10,233
$59.99 
$613,839
50,001-100,000
1,716
1
1,716
$59.99 
$102,936
100,001-1,000,000
1,266
1
1,266
$59.99 
$75,943
>1,000,000
72
1
72
$59.99 
$4,319
State 3-year Total
200,841
not applicable
200,841
not applicable
$12,047,686
Annual Average
66,947
not applicable
66,947
not applicable
$4,015,895
Notes: Detail may not add exactly to total due to independent rounding. Any inventory submitted by systems with EPA primacy will be reviewed by EPA Regional staff. LCRI modeling does not track the number of systems reporting to EPA as the primacy agency. 
Exhibit 18. Burden and Costs for States to Review Service Line Replacement Plans
System Type (service population size category, type)
Responses (Reviews)
Burden per Response (hours)
Burden (hours)
Labor Rate (2022 USD/hour)
Cost (2022 USD)
<=100, CWS
5,453
6
32,718
$59.99 
$1,962,628
101-500, CWS
7,077
6
42,462
$59.99 
$2,547,133
501-1,000, CWS
2,596
6
15,576
$59.99 
$934,345
1,001-3,300, CWS
3,876
6
23,256
$59.99 
$1,395,039
3,301-10,000, CWS
3,193
10
31,930
$59.99 
$1,915,359
10,001-50,000, CWS
2,384
18
42,912
$59.99 
$2,574,127
50,001-100,000, CWS
435
18
7,830
$59.99 
$469,692
100,001-1,000,000, CWS
322
18
5,796
$59.99 
$347,680
>1,000,000, CWS
24
18
432
$59.99 
$25,914
<=100, NTNCWS
233
6
1,398
$59.99 
$83,861
101-500, NTNCWS
164
6
984
$59.99 
$59,026
501-1,000, NTNCWS
39
6
234
$59.99 
$14,037
1,001-3,300, NTNCWS
22
6
132
$59.99 
$7,918
3,301-10,000, NTNCWS
4
6
24
$59.99 
$1,440
10,001-50,000, NTNCWS
1
6
6
$59.99 
$360
50,001-100,000, NTNCWS
n/a
n/a
n/a
n/a
n/a
100,001-1,000,000, NTNCWS
n/a
n/a
n/a
n/a
n/a
>1,000,000, NTNCWS
n/a
n/a
n/a
n/a
n/a
System 3-year Total
25,823
not applicable
205,690
not applicable
$12,338,559
Annual Average
not applicable
not applicable
68,563
not applicable
$4,112,853
Notes: Detail may not add exactly to total due to independent rounding. Any plan submitted by systems with EPA primacy will be reviewed by the EPA Regional staff. LCRI modeling does not track the number of systems reporting to the EPA as the primacy agency.



Exhibit 19. Burden and Costs for States to Review SLR Deferred Deadlines
System Type (service population size category, type)
Responses (Reviews)
Burden per Response (hours)
Burden (hours)
Labor Rate (2022 USD/hour)
Cost (2022 USD)
<=100, CWS
n/a
n/a
n/a
n/a
n/a
101-500, CWS
1
1.5
2
$59.99 
$90
501-1,000, CWS
n/a
n/a
n/a
n/a
n/a
1,001-3,300, CWS
0.33
1.5
0.5
$59.99 
$30
3,301-10,000, CWS
n/a
n/a
n/a
n/a
n/a
10,001-50,000, CWS
0.33
2.5
0.83
$59.99 
$49
50,001-100,000, CWS
n/a
n/a
n/a
n/a
n/a
100,001-1,000,000, CWS
n/a
n/a
n/a
n/a
n/a
>1,000,000, CWS
3
4.5
14
$59.99 
$810
System 3-year Total
5
not applicable
16
not applicable
$979
Annual Average
not applicable
not applicable
5
not applicable
$326
Notes: Detail may not add exactly to total due to independent rounding. Any plan submitted by systems with EPA primacy will be reviewed by the EPA Regional staff. LCRI modeling does not track the number of systems reporting to the EPA as the primacy agency.
Exhibit 20. Burden and Costs for States to Provide Templates and Review Public Education Materials
System Type (service population size category, type)
Responses
Burden per Response (hours)
Burden (hours)
Labor Rate (2022 USD/hour)
Cost (2022 USD)
<=100, CWS
5,453
0.88
4,771
$59.99 
$286,217
101-500, CWS
7,077
0.88
6,192
$59.99 
$371,457
501-1,000, CWS
2,596
0.88
2,272
$59.99 
$136,259
1,001-3,300, CWS
3,876
0.88
3,392
$59.99 
$203,443
3,301-10,000, CWS
3,193
0.88
2,794
$59.99 
$167,594
10,001-50,000, CWS
2,384
0.88
2,086
$59.99 
$125,131
50,001-100,000, CWS
435
2.38
1,033
$59.99 
$61,973
100,001-1,000,000, CWS
322
2.38
765
$59.99 
$45,874
>1,000,000, CWS
24
2.38
57
$59.99 
$3,419
<=100, NTNCWS
233
0.88
204
$59.99 
$12,230
101-500, NTNCWS
164
0.88
144
$59.99 
$8,608
501-1,000, NTNCWS
39
0.88
34
$59.99 
$2,047
1,001-3,300, NTNCWS
22
0.88
19
$59.99 
$1,155
3,301-10,000, NTNCWS
4
0.88
4
$59.99 
$210
10,001-50,000, NTNCWS
1
0.88
1
$59.99 
$52
50,001-100,000, NTNCWS
n/a
n/a
n/a
n/a
n/a
100,001-1,000,000, NTNCWS
n/a
n/a
n/a
n/a
n/a
>1,000,000, NTNCWS
n/a
n/a
n/a
n/a
n/a
System 3-year Total
25,823
not applicable
23,767
not applicable
$1,425,669
Annual Average
not applicable
not applicable
7,922
not applicable
$475,223
Notes: Detail may not add exactly to total due to independent rounding. Any material submitted by systems with EPA primacy will be reviewed by the EPA Regional staff. LCRI modeling does not track the number of systems reporting to the EPA as the primacy agency.
Exhibit 21. Burden and Costs for States to Review Updated Tap Sampling Plan
Respondent service population size category and type
Responses
Burden per Response (hours)
Burden (hours)
Labor Rate 2022 USD/hour)
Cost (2022 USD)
<=100, CWS, no service lines with lead content or GRR
6,279
1.00
6,279
$59.99 
$376,653
<=100, CWS, service lines with lead content or GRR
5,453
4.00
21,812
$59.99 
$1,308,419
101-500, CWS, no service lines with lead content or GRR
8,007
1.00
8,007
$59.99 
$480,309
101-500, CWS, service lines with lead content or GRR
7,077
4.00
28,308
$59.99 
$1,698,089
501-1,000, CWS, no service lines with lead content or GRR
2,734
1.00
2,734
$59.99 
$164,002
501-1,000, CWS, service lines with lead content or GRR
2,596
4.00
10,384
$59.99 
$622,897
1,001-3,300, CWS, no service lines with lead content or GRR
4,091
1.00
4,091
$59.99 
$245,403
1,001-3,300, CWS, service lines with lead content or GRR
3,876
4.00
15,504
$59.99 
$930,026
3,301-10,000, CWS, no service lines with lead content or GRR
1,833
2.00
3,666
$59.99 
$219,909
3,301-10,000, CWS, service lines with lead content or GRR
3,193
8.00
25,544
$59.99 
$1,532,287
10,001-50,000, CWS, no service lines with lead content or GRR
990
2.00
1,980
$59.99 
$118,773
10,001-50,000, CWS, service lines with lead content or GRR
2,384
8.00
19,072
$59.99 
$1,144,057
50,001-100,000, CWS, no service lines with lead content or GRR
136
2.00
272
$59.99 
$16,316
50,001-100,000, CWS, service lines with lead content or GRR
435
10.00
4,350
$59.99 
$260,940
100,001-1,000,000, CWS, no service lines with lead content or GRR
99
3.00
297
$59.99 
$17,816
100,001-1,000,000, CWS, service lines with lead content or GRR
322
10.00
3,220
$59.99 
$193,156
>1,000,000, CWS, no service lines with lead content or GRR
n/a
n/a
n/a
n/a
n/a
>1,000,000, CWS, service lines with lead content or GRR
24
10.00
240
$59.99 
$14,397
<=100, NTNCWS, no service lines with lead content or GRR
8,155
1.00
8,155
$59.99 
$489,187
<=100, NTNCWS, service lines with lead content or GRR
233
4.00
932
$59.99 
$55,907
101-500, NTNCWS, no service lines with lead content or GRR
6,216
1.00
6,216
$59.99 
$372,874
101-500, NTNCWS, service lines with lead content or GRR
164
4.00
656
$59.99 
$39,351
501-1,000, NTNCWS, no service lines with lead content or GRR
1,539
1.00
1,539
$59.99 
$92,319
501-1,000, NTNCWS, service lines with lead content or GRR
39
4.00
156
$59.99 
$9,358
1,001-3,300, NTNCWS, no service lines with lead content or GRR
849
1.00
849
$59.99 
$50,928
1,001-3,300, NTNCWS, service lines with lead content or GRR
22
4.00
88
$59.99 
$5,279
3,301-10,000, NTNCWS, no service lines with lead content or GRR
158
2.00
316
$59.99 
$18,956
3,301-10,000, NTNCWS, service lines with lead content or GRR
4
8.00
32
$59.99 
$1,920
10,001-50,000, NTNCWS, no service lines with lead content or GRR
36
2.00
72
$59.99 
$4,319
10,001-50,000, NTNCWS, service lines with lead content or GRR
1
8.00
8
$59.99 
$480
50,001-100,000, NTNCWS, no service lines with lead content or GRR
1
2.00
2
$59.99 
$120
50,001-100,000, NTNCWS, service lines with lead content or GRR
n/a
n/a
n/a
n/a
n/a
100,001-1,000,000, NTNCWS, no service lines with lead content or GRR
1
3.00
3
$59.99 
$180
100,001-1,000,000, NTNCWS, service lines with lead content or GRR
n/a
n/a
n/a
n/a
n/a
>1,000,000, NTNCWS, no service lines with lead content or GRR
n/a
n/a
n/a
n/a
n/a
>1,000,000, NTNCWS, service lines with lead content or GRR
n/a
n/a
n/a
n/a
n/a
System 3-year Total
66,947
not applicable
174,784
not applicable
$10,484,626
Annual Average
not applicable
not applicable
58,261
not applicable
$3,494,875
Notes: Detail may not add exactly to total due to independent rounding. Any material submitted by systems with EPA primacy will be reviewed by the EPA Regional staff. LCRI modeling does not track the number of systems reporting to the EPA as the primacy agency. Note system size strata with n/a in data cells have no systems in the size category.
Based on the estimated burden and cost presented above for States, Exhibit 22 presents the labor costs to States for each of the activities conducted during the three years covered by this ICR.
Exhibit 22. States Total Burden and Costs for the Final LCRI ICR
Requirement
Burden (Hours)
Total Cost
(2022 USD)
State implementation activities (read rule, adopt rule, modify data systems, provide training)
399,168
$23,944,566 
State reviews updated initial inventories (baseline inventories) with connector information
200,841
$12,047,686 
State reviews service line replacement plan
205,690
$12,338,559 
State reviews information on deferred deadline and associated replacement rate in the SLR plan and determine fastest feasible rate 
16
$979 
State provides a template to systems for public education on service lines with lead, GRR, or unknown content and reviews developed material
23,767
$1,425,669 
State reviews updated tap sampling plan
174,784
$10,484,626 
State Total
1,004,266
$60,242,085 


System Type (service population size category, type)
Responses (Reviews)
Burden per Response (hours)
Burden (hours)
Labor Rate (2022 USD/hour)
Cost (2022 USD)
<=100, CWS
5,624
6
33,744
$59.99 
$2,024,174
101-500, CWS
7,223
6
43,338
$59.99 
$2,599,681
501-1,000, CWS
2,574
6
15,444
$59.99 
$926,427
1,001-3,300, CWS
3,871
6
23,226
$59.99 
$1,393,239
3,301-10,000, CWS
3,114
10
31,140
$59.99 
$1,867,970
10,001-50,000, CWS
2,392
10
23,920
$59.99 
$1,434,870
50,001-100,000, CWS
422
18
7,596
$59.99 
$455,655
100,001-1,000,000, CWS
318
18
5,724
$59.99 
$343,361
>1,000,000, CWS
24
18
432
$59.99 
$25,914
<=100, NTNCWS
204
6
1,224
$59.99 
$73,423
101-500, NTNCWS
171
6
1,026
$59.99 
$61,546
501-1,000, NTNCWS
34
6
204
$59.99 
$12,237
1,001-3,300, NTNCWS
24
6
144
$59.99 
$8,638
3,301-10,000, NTNCWS
4
6
24
$59.99 
$1,440
10,001-50,000, NTNCWS
1
6
6
$59.99 
$360
50,001-100,000, NTNCWS
0
0
0
$0
$0
100,001-1,000,000, NTNCWS
0
0
0
$0
$0
>1,000,000, NTNCWS
0
0
0
$0
$0
System 3-year Total
26,000
not applicable
187,192
not applicable
$11,228,934
Annual Average
not applicable
not applicable
62,397
not applicable
$3,742,978
Notes: Detail may not add exactly to total due to independent rounding. Any plan submitted by systems with EPA primacy will be reviewed by EPA Regional staff. LCRI modeling does not track the number of systems reporting to EPA as the primacy agency.
The total State burden and costs shown above also double count requested burden and costs for the LCRR in the Information Collection Request for the Lead and Copper Rule Revisions (OMB Control Number 2040-0297, EPA Tracking Number 2606.03) for the review of service line replacement plans, and the provision of public education templates and review of system developed education materials for customers on service lines with lead, GRR, or unknown material. Therefore, the EPA applied a multiplicative factor of 16/36 to the LCRR ICR’s total burden and cost estimates to estimate the potential overlap with this LCRI ICR. See the PWS net cost calculation description above for additional details. The EPA subtracted the prorated values from the LCRR to estimate the net total and annual average burden and costs (see Exhibit 23) for the final LCRI ICR. 


Exhibit 23. States Net Total and Average Annual Burden and Costs for the Final LCRI ICR
Item
Responses
Total Burden
Total Costs
(2022 USD)
[a] Total for LCRR ICR Renewal (USEPA 2022) – All Activities
2,098,812
3,783,245
$252,769,014
[b] Estimated Overlap with LCRR ICR Renewal ([a] x 16/36)
              932,805 
            1,681,442 
$112,341,784
[c] Total for final LCRI ICR – All Activities
319,663
1,004,266
$60,242,085
[d] Net Total for final LCRI ICR – All Activities ([c] – [b])
             -613,143
              -677,176
-$52,099,699
Net Average Annual for final LCRI ICR – All Activities ([d]/3)
        -204,381
         -225,725
-$17,366,566


Total Combined Burden and Costs
This section provides a description of bottom-line estimates for implementation of the final LCRI over the first three years following rule promulgation. As the LCRI implementation period overlaps with the LCRR renewal and supplemental ICR, the bottom-line estimates remove the double-counted burden. The bottom-line burden hours and costs for systems and States are the summaries of the hours and costs collectively incurred for all activities. The first part of this section describes the estimated costs and hourly burdens for respondents to the final rule. The second part discusses the potential cost and burden to EPA. Exhibit 21 presents a summary of the total respondent burden over three years for PWSs and states. 
Exhibit 21. Bottom Line Total Burden and Costs
(2022 USD)
Number of Respondents
67,003 =
66,947
+56

Public water systems
States 
Number of Responses
966,477 =
1,568,217
-601,740

Public water systems
States 
Total Respondent Burden Hours
-4,450,908 =
-3,619,563
-831,345

Public water system hours
State hours
Hours per System
for Public Water Systems
-54.07 =
-3,619,563
/66,947

Total PWS hours from above
Total PWS from above
Hours per State for States
-14,845 = 
-831,345
/56

Total state hours from above
Total states from above
Total Respondent Cost
$201,370,609 =
$262,718,315
-$61,347,706

Public water system costs
State costs
Average Cost per System for Public Water Systems
$3,924 =
$262,718,315
/66,947

Total PWS costs from above
Total PWS from above
Average Cost per State for States
-$1,095,495 = 
-$61,347,706
/56

Total state costs from above
Total states from above
Note: Detail may not add exactly to total due to independent rounding. 
For the first three years after the final rule is published, the average burden associated with this ICR is estimated to be 2,809,824 burden hours per year. The corresponding average total respondent costs are estimated to be $371,746,927 per year. 
EPA estimates the average respondent burden for PWSs to be 2,526,459 hours per year. Respondent costs for PWSs are estimated to be $354,748,901 per year. The Agency estimates that the burden for states is 283,366 hours per year. The corresponding costs for states are estimated to be $16,998,026 per year.
The net average burden is estimated to be -1,483,636 burden hours per year. The corresponding net average total respondent costs are estimated to be $67,123,536 per year. 
EPA estimates the net average respondent burden for PWSs to be -1,206,521 per year. Net respondent costs for PWSs are estimated to be $87,572,772 per year. The Agency estimates that the burden for states is -277,155 hours per year. The corresponding costs for states are estimated to be -$20,449,235 per year.
EPA assumes the rule implementation and public education materials development activities will take place in the first year, development and submission to the State of the service line replacement plan is assumed to occur in the third year, while the implementation of the service line inventory and public education distribution requirements are spread uniformly over the first three years. Exhibit 22 and Exhibit 23 show the resulting distribution of burden and cost, respectively.
Exhibit 22. Distribution of Burden over the ICR Period
Requirement
Year 1 Burden (hours)
Year 2 Burden (hours)
Year 3 Burden (hours)
System implementation activities (read rule, assign staff, attend training)
1,338,940
0
0
Systems review records for connector material to prepare the updated initial inventory
1,468,961
1,468,961
1,468,961
Systems submit the updated initial inventory with connector information
127,063
127,063
127,063
Systems conduct normal and field operations to update unknown service lines
not applicable
not applicable
not applicable
Systems update and submit inventory to state annually
26,000
26,000
26,000
Systems develop and submit a service line replacement plan
0
0
374,384
Systems develop public education materials for customers on service lines with lead, GRR, or unknown content and submit to states for review
182,000
0
0
Systems distribute public education materials for customers on service lines with lead or unknown content
272,660
272,660
272,660
System Subtotal
3,415,624
1,894,684
2,269,068
System Estimated Overlap of Average Annual for LCRR ICR Renewal
3,732,980
3,732,980
3,732,980
System Net Subtotal
-317,356
-1,838,296
-1,463,912
State implementation activities (read rule, adopt rule, modify data systems, provide training)
133,056
133,056
133,056
State reviews updated initial inventories with connector information
66,947
66,947
66,947
State review annual inventory update
13,000
13,000
13,000
State reviews service line replacement plan
0
0
187,192
State provides templates to systems for public education on service lines with lead, GRR, or unknown content and reviews system developed materials
23,896
0
0
State Subtotal
236,899
213,003
400,195
State Estimated Overlap of Average Annual for LCRR ICR Renewal
560,481
560,481
560,481
State Net Subtotal
-323,582
-347,478
-160,286
Combined Systems and State
3,652,523
2,107,687
2,669,263
Combined Systems and State Net Total
-640,937
-2,185,773
-1,624,197

Exhibit 23. Distribution of Cost over the ICR Period (2022 USD)
Requirement
Year 1 Burden (cost)
Year 2 Burden (cost)
Year 3 Burden (cost)
System implementation activities (read rule, assign staff, attend training)
$50,720,720 
$0 
$0 
Systems review records for connector material to prepare the updated initial inventory
$72,417,808 
$72,417,808 
$72,417,808 
Systems submit the updated initial inventory with connector information
$4,865,587 
$4,865,587 
$4,865,587 
Systems conduct normal and field operations to update unknown service lines
$229,736,236 
$229,736,236 
$229,736,236 
Systems update and submit inventory to State annually
$1,009,845 
$1,009,845 
$1,009,845 
Systems develop and submit a service line replacement plan
$0 
$0 
$15,081,002 
Systems develop public education materials for customers on service lines with lead, GRR, or unknown content and submit to States for review
$7,068,916 
$0 
$0 
Systems distribute public education materials for customers on service lines with lead or unknown content
$22,429,212 
$22,429,212 
$22,429,212 
System Subtotal
$388,248,325 
$330,458,689 
$345,539,691 
System Estimated Overlap of Average Annual for LCRR ICR Renewal
$267,176,130 
$267,176,130 
$267,176,130 
System Net Subtotal
$121,072,195 
$63,282,559 
$78,363,561 
State start-up activities (read rule, adopt rule, modify data systems, provide training)
$7,981,522 
$7,981,522 
$7,981,522 
State reviews updated initial inventories with connector information
$4,015,895 
$4,015,895 
$4,015,895 
State review annual inventory update
$779,820 
$779,820 
$779,820 
State reviews service line replacement plan
$0 
$0 
$11,228,934 
State provides templates to systems for public education on service lines with lead, GRR, or unknown content and reviews system developed materials
$1,433,430 
$0 
$0 
State Subtotal
$14,210,668 
$12,777,238 
$24,006,172 
State Estimated Overlap of Average Annual for LCRR ICR Renewal
$37,447,261 
$37,447,261 
$37,447,261 
State Net Subtotal
-$23,236,594
-$24,670,023
-$13,441,089
Combined Systems and State
$402,458,993
$343,235,927
$369,545,863
Combined System and State Net Subtotal
$97,835,602
$38,612,535
$64,922,472



    13. Respondent CAPITAL AND O&m CostS 
Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).
The cost estimate should be split into two components: (a) a total capital and start-up cost
component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should consider costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling, and testing equipment; and record storage facilities.
If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate. 
Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.
 PWSs will incur non-labor costs associated with the tasks of identifying unknown service lines through normal operations and targeted field investigations (See Exhibit 8) and distributing public education materials to customers serviced by LSL, GRR, and unknown material service lines (see Exhibit 12). The total non-labor costs for respondents is estimated to be $720,675,962 or $240,225,321 on average annually (See Exhibit 13). These costs are incorporated into the total and net costs described in Exhibits 21-23. 
    14. AGENCY COSTS
Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.
14a. Agency Activities
The Agency is responsible for promulgating and overseeing the implementation of the LCRI. The Agency is involved in the following activities that assist States in implementing the modifications:
    • Develop the revised regulations,
    • Respond to questions on the revised regulations, and
    • Collect data at the national level in SDWIS.
The Agency will also conduct primacy activities for States, tribes, and territories that do not have primacy. Specifically, EPA Regions will be involved in the following activities:
    • Reviewing lead service line replacement plans.
    • Reviewing updated initial inventories with lead connector information.
    • Reviewing annual updates of the service line inventories.
    • Providing templates and reviewing public education material.
However, burden and costs for these activities are accounted for under the State burden.  
14b. Agency Labor Cost
The Agency will conduct primacy activities in States, Tribes, and territories that do not have primacy. However, burden and costs for these activities are accounted for under the State burden. Additional information-related activities that may be undertaken by both EPA headquarters and regional offices include reviewing, interpreting, and explaining the new regulations to states that ask for guidance. For example, during the implementation process, EPA headquarters or regions might be asked for explanations or interpretations of the intent of the new regulations. EPA believes that these regulatory changes are relatively straightforward and limited in scope and expects that the preamble language will generally be sufficient for the purpose of explaining EPA’s intent. Therefore, the additional burden incurred by headquarters and regional offices is expected to be minimal.
Further, the additional burden and costs incurred by EPA’s drinking water program at headquarters and regional offices to assist states in implementing drinking water regulations are already included in existing ICRs. EPA burden and costs for ongoing regulatory development and support activities for all EPA drinking water regulations are accounted for under the Public Water System Supervision Program ICR.5 This final rule does not create any additional Agency burden beyond that which is already described in the latest version of the PWS Supervision Program ICR (2040-0090, EPA ID 1895.10).
14c. Agency Non-Labor Costs
Any additional burden or cost that EPA may incur as a result of the final LCRI implementation activities is expected to be minimal and is already accounted for in existing ICRs. 
    15) REASONS FOR CHANGE IN BURDEN
Explain the reasons for any program changes or adjustments reported in the burden or capital/O&M cost estimates.
The final LCRI requirements are intended to strengthen the LCRR in the areas of CCT, customer awareness, and service line replacement. The changes are expected to ensure and enhance the protection of public health through the reduction in lead exposure in drinking water. EPA needs comprehensive and current information on lead and copper occurrence and exposure and associated enforcement activities to implement its program oversight and enforcement responsibilities mandated by the SDWA. States need the information to identify significant sources of lead that might threaten the health and safety of drinking water consumers in a timely fashion. 
Over the next three years, the final LCRI would require respondents to undertake some actions requested in the ICR entitled Information Collection Request for the Lead and Copper Rule Revisions (OMB Control Number 2040-0297, EPA Tracking Number 2606.03) and additional actions beyond those covered in the LCRR ICR. In total these final LCRI requirements would decrease the burden by approximately 1.48 million hours and increase the cost by $67.12 million annually over the next three years when compared to the LCRR ICR. 
    16) PUBLICATION OF DATA
For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
The Agency does not intend to publish information gathered through this information collection.
    17) DISPLAY OF EXPIRATION DATE 
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
The Agency plans to display the expiration date for OMB approval of the information collection on all instruments.
    18) CERTIFICATION STATEMENT
Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”
This information collection complies with all provisions of the Certification for Paperwork Reduction Act Submissions.

APPENDIX A: SDWA Sections that Provide Authority for the Collection
Section 1401. For purposes of this title:

(1) The term “primary drinking water regulation” means a regulation which-

(D) contains criteria and procedures to assure a supply of drinking water which dependably complies with such maximum contaminant levels; including accepted methods for quality control and testing procedures to insure compliance with such levels and to insure proper operation and maintenance of the system, and requirements as to (i) the minimum quality of water which may be taken into the system and (ii) siting for new facilities for public water systems. At any time after promulgation of a regulation referred to in this paragraph, the Administrator may add equally effective quality control and testing procedures by guidance published in the Federal Register. Such procedures shall be treated as an alternative for public water systems to the quality control and testing procedures listed in the regulation.

Section 1413(a) For purposes of this title, a state has primary enforcement responsibility for public water systems during any period for which the Administration determines (pursuant to regulations under subsection (b)) that such state-

(1) has adopted drinking water regulations that are no less stringent than the national primary drinking water regulations promulgated by the Administrator under subsections (a) and (b) of section 1412 not later than 2 years after the date on which the regulations are promulgated by the Administrator, except that the Administrator may provide for an extension of not more than 2 years if, after submission and review of appropriate, adequate documentation from the state, the Administrator determines that the extension is necessary and justified;

(2) has adopted and is implementing adequate procedures for the enforcement of such state regulations, including conducting such monitoring and making such inspections as the Administrator may require by regulation;

(3) will keep such records and make such reports with respect to its activities under paragraphs (1) and (2) as the Administrator may require by regulation.

Section 1445 (a)(1)(A) Every person who is subject to any requirement of this title or who is a grantee, shall establish and maintain such records, make such reports, conduct such monitoring, and provide such information as the Administrator may reasonably require by regulation to assist the Administrator in establishing regulations under this title, in determining whether such person has acted or is acting in compliance with this title, in administering any program of financial assistance under this title, in evaluating the health risks of unregulated contaminants, or in advising the public of such risks. In requiring a public water system to monitor under this subsection, the Administrator may take into consideration the system size and the contaminants likely to be found in the system's drinking water.

(B) Every person who is subject to a national primary drinking water regulation under section 1412 shall provide such information as the Administrator may reasonably require, after consultation with the state in which such person is located if such state has primary enforcement responsibility for public water systems, on a case-by-case basis, to determine whether such person has acted or is acting in compliance with this title.

(C) Every person who is subject to a national primary drinking water regulation under section
1412 shall provide such information as the Administrator may reasonably require to assist the Administrator in establishing regulations under section 1412 of this title, after consultation with states and suppliers of water. The Administrator may not require under this subparagraph the installation of treatment equipment or process changes, the testing of treatment technology, or the analysis or processing of monitoring samples, except where the Administrator provides the funding for such activities. Before exercising this authority, the Administrator shall first seek to obtain the information by voluntary submission.

(D) The Administrator shall not later than 2 years after the date of enactment of this subparagraph, after consultation with public health experts, representatives of the general public, and officials of state and local governments, review the monitoring requirements for not fewer than 12 contaminants identified by the Administrator, and promulgate any necessary modifications.